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ARTICLE · 04 AUGUST 2026

ESMA Publishes Preliminary Findings On The Active Account Requirement

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ESMA has published its first substantive assessment of how the Active Account Requirement is reshaping central clearing in the EU, revealing widespread adoption among roughly 500 market participants and early signs of clearing activity migrating from UK CCPs to EU counterparties. The findings offer preliminary insights into a regulatory framework designed to reduce EU dependencies on third-country central counterparties, with implications for both EU and UK financial institutions navigating this evolving la

GlobalFinance and Banking
Christopher Collins
Christopher Collins
Carolyn Jackson
Carolyn Jackson
Nathaniel Lalone
Nathaniel Lalone
Neil Robson
Neil Robson
Ciara Watson
Ciara Watson
Eleanor Bines
Eleanor Bines
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Introduction

On 6 July 2026, the European Securities and Markets Authority (ESMA) published two important documents on recent developments concerning central clearing in the European Union (EU): the Interim Report on the effectiveness of the Active Account Requirement (AAR) and the first Annual Report of the Joint Monitoring Mechanism (JMM). Together, these publications offer the first substantive read on how the AAR is reshaping the EU clearing landscape. 

ESMA’s Key Findings

The AAR was introduced by a 2024 package of amendments to the European Market Infrastructure Regulation (EMIR 3.0). The purpose of the AAR is to reduce perceived dependencies by EU market participants on certain important “Tier 2” central counterparties (CCPs) located in third countries, principally the United Kingdom. The Interim Report presents preliminary findings on AAR implementation during 2025 and early 2026.

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