ARGA Observatory has submitted a formal expert response as part of the public consultation conducted by the European Securities and Markets Authority (ESMA) on the draft regulatory technical standards under EMIR (Article 37(7)) concerning participation requirements in central counterparties (CCPs).
The response sets out ARGA Observatory’s position based on the principles of risk-based regulation and proportionality, addressing fair access to clearing, the financial and operational resilience of clearing members, sponsored clearing models, liquidity requirements, and alternative eligibility criteria for non-financial counterparties. The document reflects ARGA Observatory’s analytical and regulatory expertise and constitutes a contribution to the EU policymaking process in the field of financial market infrastructure and systemic risk regulation.