No less than three substantive pieces of EU legislation have been proposed over the eight-month period from November 2016 to June 2017, modifying or complementing the original EMIR Regulation of 2012. This contribution analyses the changes that have taken place in EU OTC derivatives markets since the new rules were adopted, and discusses the three drafts. It argues that the European Commission should have assessed risk management with CCPs in more detail and should have proposed a more integrated architecture for the supervision and resolution of CCPs. It further argues that the three proposals should have been part of one single package to facilitate the legislative process of such technical measures.

Karel Lannoo is Chief Executive of CEPS and General Manager of ECMI.