The Dutch Authority for the Financial Markets (AFM) and De Nederlandsche Bank (DNB) have reminded institutions subject to the clearing obligation that meet the conditions in Article 7 bis(1) of EMIR 3 that they must submit their first report on compliance with the active account requirement by 31 July 2026. The first reporting cycle covers the period from 25 June 2025 to 30 June 2026. Technical regulatory standards for the active account requirement have applied since 26 February 2026. Although ESMA’s reporting tables annexes are not yet formally applicable for this first submission, the supervisors are asking firms to already use the tables in the technical standards to support consistent and comparable data quality; ESMA has also issued additional guidance on the representativeness obligation, including how to identify relevant derivatives subcategories, assess compliance and complete the templates. ESMA has published a template that becomes mandatory from the second reporting onwards. For firms supervised by the AFM, the supervisors request submission by email in CSV format, with questions directed to the firm’s account supervisor.
Dutch Authority for the Financial Markets 2026-04-17
Dutch Authority for the Financial Markets and De Nederlandsche Bank require first EMIR 3 active account requirement report by 31 July 2026
The Dutch Authority for the Financial Markets and De Nederlandsche Bank reminded institutions subject to the clearing obligation and meeting Article 7 bis(1) EMIR 3 conditions that their first report on compliance with the active account requirement is due for 25 June 2025 to 30 June 2026. Technical regulatory standards have applied since 26 February 2026, and although ESMA reporting tables are not yet formally applicable, supervisors expect firms to already use these templates and follow ESMA’s guidance on the representativeness obligation. Reports to the Dutch Authority for the Financial Markets should be submitted by email in CSV format.