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The derivatives industry is also welcoming improvements to the stress testing requirements within the EU’s new derivatives regulations. Bill Stenning of Societe Generale indicated that the final rules are expected to “reduce the operational burden of stress tests for clearinghouses, clearing members and their end-clients,” and may even allow end-clients to outsource this procedure to their clearing member.
Kirston Winters, head of legal, risk, compliance, and government and regulatory affairs at OSTTRA, echoed this sentiment, stating that “ESMA has… made several much-needed changes to reduce the unnecessary burden of the AAR.”
While the European Commission has a three-month window to formally adopt ESMA’s final version of the Active Account Requirement (AAR), Ulrich Karl, head of clearing at ISDA, emphasized that firms should already be operating under the new rules. He clarified that “the Level 1 text is already live as of June 24,” meaning the foundational regulatory framework is in effect. This suggests that while the finer details of the AAR’s implementation, as specified in ESMA’s Regulatory Technical Standards (RTS), are now finalized, the overarching obligation stemming from the EMIR 3 Level 1 text has been in force since that date.
The AAR mandates that EU firms with significant euro derivatives exposures hold an active account at an EU clearinghouse and clear a minimum number of trades there annually. This initiative is a core part of the EU’s strategy to enhance its financial stability and reduce reliance on third-country Central Counterparties (CCPs) for euro-denominated derivatives clearing, particularly following Brexit.

Video courtesy of CSOB

https://www.youtube.com/live/4um8f-JhMOI?si=G64jI4HL4yUE6fJD

Video courtesy of CSOB