Article
EMIR 3.0: Changes To The Clearing Threshold Regime
The European Commission has adopted a delegated regulation amending the clearing threshold framework under EMIR 3.0, fundamentally shifting regulatory focus from overall OTC derivatives activity to uncleared exposure risk. Financial counterparties must now perform two distinct calculations—an aggregate OTC position test and a new uncleared OTC position test—while non-financial counterparties face only the uncleared test, creating stronger incentives for central clearing through CCPs.

Dillon Eustace




