EBF, ISDA, AFME, AND ICMA Publish Paper on Proposals Relating to MIFIR PTT in the EC’s Market Integration and Supervision Package
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Brussels, 7 April 2026 – The European Banking Federation (EBF), the International Swaps and Derivatives Association (ISDA), the Association for Financial Markets in Europe (AFME) and the International Capital Market Association (ICMA) published a paper on proposals relating to post-trade transparency (PTT) under the Markets in Financial Instruments Regulation (MiFIR), as part of the European Commission’s (EC) Market Integration and Supervision Package.
The paper supports the EC’s proposal to remove forward rate agreements and basis swaps from the scope of public transparency, given their illiquid nature, and provides supporting arguments in this regard. It also supports the proposal to disapply MiFIR PTT requirements for over-the-counter derivatives concluded on certain third-country trading venues, effectively superseding the existing European Securities and Markets Authority (ESMA) opinion.
However, the paper calls on the EC and co-legislators to be more ambitious by extending the scope of the proposal to all asset classes currently subject to PTT, and by disapplying PTT to transactions executed outside trading venues and made public through suitably qualified third-country approved publication arrangements.
For more information:
Jacopo Borgognone, Head of Capital Markets – j.borgognone@ebf.eu
About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The federation is committed to a thriving European economy that is underpinned by a stable, secure, and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.




