Final Report on Technical Standards for Post-Trade Risk Reduction Services Under EMIR (European Securities and Markets Authority)

Summary

• EMIR 3 was published in the Official Journal on 4 December 2024 and entered into force 20 days after publication.p.8
• The exemption from the clearing obligation entered into application on 24 December 2024.p.8
• ESMA submitted the Final Report to the European Commission on 9 October 2026.p.9
• The European Commission has 3 months to decide whether to endorse the proposed RTS.p.9
• The open consultation received 4 responses prior to closing on 20 April 2026.p.11
• ESMA was mandated to submit draft regulatory technical standards to the Commission by 25 December 2025.p.14

Key insights

1. EMIR 3 introduces a conditional exemption from the clearing obligation for transactions resulting from PTRR services such as portfolio compression, portfolio rebalancing, and basis risk optimisation.p.10
2. Market risk neutrality in a PTRR exercise requires preserving the overall market risk of each submitted portfolio before and after the exercise within minimal tolerances.p.20
3. To prevent circumvention of the clearing obligation, a PTRR exercise must not result in an increase of aggregate net uncleared risk in any submitted portfolio.p.24
4. PTRR service providers are required to be MiFID authorised investment firms and maintain a dedicated policy section covering potential conflicts of interest.p.29
5. Participation in a PTRR exercise is restricted to entities that initially submitted a portfolio, and proposed outputs must be accepted in full or rejected without partial execution.p.30
6. PTRR service providers must keep complete records of transactions executed pursuant to a PTRR exercise, including market risk neutrality evidence and assigned PTRR IDs.p.43
7. Competent authorities monitor the PTRR exemption using annual compliance reports and notifications of material changes submitted by PTRR service providers.p.45