Implementation of the AAR reporting requirements

A new notice has been published on the ESMA website regarding the implementation of the Active Account Requirement (AAR) introduced by EMIR 3.0.

For banks acting as KDPW_CCP clearing members for OTC derivatives, this results in key strict reporting deadlines in accordance with the following reporting calendar:

1. 31 July 2026 – banks must submit their first AAR report to the Polish Financial Supervision Authority (KNF) by this date. The report will cover the period from 25 June 2025 (the date when the AAR requirement became legally binding) to 30 June 2026;
2. Semi-annual reporting cycle for subsequent reports – these must be submitted on 31 January and 31 July of each year, with each report aggregating data for a 12-month reference period.

The main objective of the EMIR 3.0 package is to mitigate risks and transfer as much of the systemic OTC clearing as possible to clearing houses located in the EU, such as KDPW_CCP.

The three main pillars of the package:

1. Operational conditions – full functionality and readiness for a significant increase in the scale of active account clearing. The operational conditions which must be met include ensuring uninterrupted IT system connectivity, up-to-date legal documentation, and tested internal clearing processes. The Bank’s active account must be ready for the immediate processing of the uninterrupted clearing of increased transaction volumes in contracts subject to the EU requirement (including those settled in PLN).
2. Representativeness obligation – if the notional value of derivative contracts cleared by the Bank exceeds the threshold of EUR 6 billion set by EMIR, transactions cleared in the active account must constitute a representative minimum of the Bank’s entire OTC derivatives portfolio, taking into account diversification by instrument category, transaction size, and maturity date.
3. Standardised data forms in accordance with the templates provided by ESMA, which include, among others: type of cleared instruments, average annual clearing volumes broken down by asset class and currency, the value of resources of the CCP clearing guarantee system, and a list of the largest payment obligations arising from current clearing activity in the active account.

More about the KDPW_CCP service
KDPW_CCP statement