Activity

EMIR 3.0, which officially entered into force on December 24, 2024, represents a pivotal policy shift by the European Commission to consolidate euro-denominated clearing within the EU. This move aims to lessen the post-Brexit reliance on UK-based central counterparties (CCPs) and is expected to drive significant long-term structural changes in clearing, monitoring, and trade reporting across Europe.
A key component of EMIR 3.0 is the “active account requirement” (AAR), which mandates in-scope EU market participants to hold and utilize an active account with an EU-based CCP for specific euro-denominated derivatives. Firms are expected to demonstrate operational readiness and have systems capable of transferring their entire book of in-scope products to an EU CCP if needed. The first compliance deadlines for the AAR are in mid to late June 2025.
According to a survey conducted by Acuiti in March and April 2025, a significant majority of firms (71%) in scope for EMIR 3.0 anticipate being ready for the June deadline. However, 9% of firms are unlikely or certainly not prepared, and over a third still had not selected the CCP they would be onboarding with.
Compliance readiness varies considerably across different financial sectors:
* Sell-side and asset management groups are reportedly the furthest along in their preparations.
* Hedge funds and proprietary trading firms are lagging behind, with a notable percentage of these firms even unsure if they fall within the scope of EMIR 3.0.
Challenges for firms in meeting the EMIR 3.0 requirements include assessing group-wide clearing activity, establishing EU clearing connectivity (including selecting a CCP/broker, completing legal agreements, and ensuring IT system connection and testing within a tight six-month window), and demonstrating operational readiness through stress tests and simulated trade transfers. Firms also need a strategy to route a minimum number of representative trades to EU CCPs and monitor activity to meet thresholds.
The implementation of EMIR 3.0 is expected to have profound implications for the European financial landscape by:
* Enhancing the resilience of EU clearing services for euro-denominated derivatives.
* Increasing the EU’s control over its financial infrastructure.
* Potentially altering existing market structures and relationships as clearing activity shifts from London to EU-based CCPs.
* Influencing strategic decisions regarding self-clearing, technology investments, and risk management frameworks for market participants.

Video courtesy of Eurex

Video courtesy of Eurex