Comment on the IDW position paper on the EMIR auditing process (in German)

We comment the draft position paper of Institut der Wirtschaftsprüfer in Deutschland (IDW) regarding the auditing process on the requirements of non-financial companies according to EMIR. So called „take-or-pay-clauses“ in contracts for the delivery of commodities should not be regarded as derivatives. Furthermore, we ask IDW for an appropriate calculation of the clearing thresholds.