Vice-President Dombrovskis
Directorate-General for Financial Stability, Financial Services and Capital Markets
European Commission
1049 Bruxelles / Brussels
Belgium

12 November 2019

Dear Vice-President Dombrovskis,

Temporary Equivalence and Recognition in relation to UK CCPs

The Joint Associations 1 are very appreciative of the work carried out by the European Commission so far to ensure that there will be continuity of access for EU members to UK central counterparties (CCPs) even in the event that the UK leaves the EU without a deal.

In particular, we welcome the Commission Implementing Decisions of 19 December 20182 which provided for temporary equivalence of the UK’s regulatory framework for CCPs and central securities depositories (CSDs) for a period up to 30 March 2020 and 30 March 2021 respectively, as well as ESMA’s recognition decisions in relation to three UK CCPs and the UK CSD.

We also appreciate the Commission’s work in finalising the changes to the recognition regime for non-EU CCPs under EMIR 2.2, which we understand is close to publication in the Official Journal. We understand that this revised framework for recognition is intended to address the Commission’s and Member States’ concerns regarding supervision of non-EU CCPs while also introducing some important protections for EU counterparties to OTC derivatives in the event that equivalence and recognition of a non-EU CCP are withdrawn.