No additional effort for the identification of OTC derivatives

In a consultation, the European Commission proposes the ‘International Security Identification Number’ (ISIN) for the identification of over-the-counter (OTC) derivatives as part of the MiFIR transparency regulations. In other regulatory regimes, in particular under the EMIR derivatives regulation, the ‘Unique Product Identifier’ (UPI) is used. Switching to ISIN would mean a great deal of effort for companies. In our statement, we therefore argued in favour of sticking to the proven practice of the UPI under EMIR and refraining from extending identification via ISIN to other regulatory regimes such as EMIR.