One of the key aims of EMIR 3 is to incentivise the development of clearing in the EU and reduce exposures to, and usage by, EU entities of third country central counterparties (CCPs). This has led to a number of changes relating to cleared derivatives including the introduction of the new, so-called “active account” requirement.

In addition to changes relating to cleared derivatives, however, EMIR 3 also makes a number of changes impacting uncleared OTC derivatives markets. We focus on these impacts in this note.