The European Commission has published a consultation for a draft Delegated Regulation to enhance transparency in over-the-counter (OTC) derivatives trading. This follows updates to the Markets in Financial Instruments Regulation (MiFIR), extending pre- and post-trade transparency requirements to both exchange-traded and OTC derivatives.

Key changes include a revised post-trade disclosure obligation for investment firms. This now covers only OTC derivatives traded by firms on their own account or for clients, excluding derivatives traded on a venue. Transaction reporting obligations continue to apply to both exchange-traded and OTC derivatives.

The draft regulation specifies the reference data needed for OTC interest rate swaps and credit default swaps, including data to be assigned to an ISO 6166 International Securities Identification Number (ISIN). The implementation date has been postponed to 1 September 2025 to allow time for necessary IT adjustments and the revision of the ISIN template.


The Commission’s consultation on reference data for transparency reporting under MiFIR Article 8a(2) resulted in a proposal that balances the use of identifiers for both transparency and transaction reporting.

The consultation is open until 10 July. If there are no objections from the EU Council or Parliament, the regulation will take effect twenty days after its publication in the Official Journal of the European Union, with full application from 1 September 2025.