In opening remarks at ISDA’s Annual Legal Forum, ISDA General Counsel Katherine Tew Darras outlined ISDA’s current legal and documentation priorities, focusing on enabling safe use of tokenized assets as margin collateral for non-cleared derivatives and finalizing an updated, consolidated set of FX and Currency Option Definitions. On tokenization, ISDA linked recent episodes of market stress to large variation margin calls and the resulting demand for cash, and argued that tokenized representations of assets on shared ledgers could expand the universe of eligible collateral and reduce operational frictions in posting assets such as money market funds. ISDA highlighted its 2023 tokenized collateral model provisions for inclusion in the 2016 credit support annexes for variation margin and a 2024 guidance note on how firms may approach legal opinions on enforceability when using tokenized collateral; it is also co-sponsoring a working group with Global Digital Finance focused on using US tokenized money market funds as collateral. The remarks referenced US developments including the Genius and Clarity Acts and recent Commodity Futures Trading Commission guidance clarifying that tokenized versions of already-eligible collateral retain margin eligibility provided existing requirements are met, alongside an emphasis on maintaining risk management standards. ISDA said the 2026 FX Definitions will be published in March 2026, with around two years for market implementation ahead of an end-2027 rollout aligned with Swift’s annual update schedule; revisions include updates to disruption events for deliverable transactions and alignment on the calculation agent standard. Other workstreams included Determinations Committees governance, with an independent regulated administrator expected to be selected before end-March 2026 following a tender process, and further adoption of the ISDA Notices Hub launched in July 2025, with nearly 160 entities adhering to the ISDA 2025 Notices Hub Protocol.

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