The European Association of CCP Clearing Houses (EACH) published a position paper on the proposed “Master Regulation” within the European Union’s Market Integration and Supervision Package, backing the package’s single market objectives while setting out targeted changes it considers necessary for workable and proportionate oversight of central counterparties (CCPs). The paper focuses on supervisory architecture, reporting simplification, outsourcing, incentives to clear, and reducing duplicative compliance burdens. On supervision, EACH supports removing supervisory colleges for significant CCPs but calls for legislative clarification that, where a CCP is directly supervised by the European Securities and Markets Authority (ESMA), decision-making powers should rest exclusively with ESMA. For less significant CCPs, it argues the proposed model would create disproportionate complexity by retaining both national competent authority (NCA) supervision and a full college, and it proposes replacing the college with a streamlined NCA-ESMA cooperation arrangement similar to mechanisms referenced in EMIR and the ESMA Regulation. On resourcing and fees, it points to the proposal’s estimate that ESMA would require 480 officials by 2034, including 47 for CCP supervision and related convergence work, and calls for proportionate, cost-effective ESMA fees, avoidance of duplicative charges by ESMA and NCAs for similar services, and earlier fee estimation to support CCP budget planning. The paper also advocates adding a global competitiveness objective to ESMA’s mandate. On reporting, EACH supports ESMA establishing a data platform and argues it should enable “report once” reporting, with data sourced from the entity best placed to provide it, supported by robust validation and audit mechanisms and operating on a cost-neutral basis. It highlights overlaps across EMIR, MiFIR, MiFID II, MAR, REMIT and SFTR reporting obligations, including areas such as energy derivatives and securities financing transactions, and notes additional complexity from overlapping non-EU regimes. It further calls for CCPs to benefit from the same outsourcing simplifications envisaged for trading venues and central securities depositories, urges amendments to fund-sector rules such as the Money Market Fund Regulation and the UCITS Directive to reduce disincentives to centrally clear repos, and recommends streamlining overlaps between the Digital Operational Resilience Act and NIS2. Beyond the immediate proposals, it flags legal uncertainty for CCP DLT use because EMIR is not addressed in the package, promotes greater settlement integration via T2S, and argues that any right to choose a settlement location should be framed as a structured choice with a clear process rather than an unconditional right.
European Association of CCP Clearing Houses 2026-03-25
European Association of CCP Clearing Houses publishes position on the EU Market Integration and Supervision Package calling for simpler CCP supervision and streamlined reporting
The European Association of CCP Clearing Houses (EACH) released a position paper on the EU's Market Integration and Supervision Package, supporting its single market goals while suggesting changes for effective CCP oversight. EACH advocates for ESMA's exclusive decision-making power over significant CCPs, streamlined NCA-ESMA cooperation for less significant CCPs, and cost-effective ESMA fees. It also calls for simplified reporting, outsourcing, legal clarity for CCP DLT use, and highlights the need for a global competitiveness objective in ESMA's mandate.