The European Securities and Markets Authority has published standardised reporting templates and instructions for the Active Account Requirement under EMIR 3, with the first submission due on 31 July 2026 covering the period from 25 June 2025 to 30 June 2026.
The publication moves the AAR into a live reporting regime. Firms in scope now have a common format, a confirmed timetable, and a first filing covering more than 12 months of activity.
After the initial submission, reporting moves to a six-month cycle with deadlines on 31 January and 31 July each year. Each filing covers a rolling 12-month reference period, meaning firms report twice a year but supervisors assess clearing behaviour across an annual window rather than a single snapshot.
Who is in scope
The AAR applies to certain OTC euro-denominated interest rate derivatives, OTC Polish zloty-denominated interest rate derivatives, and euro-denominated short-term interest rate derivatives. It became applicable on 25 June 2025.
The regime has two core components. The first is an operational obligation requiring firms to maintain an appropriate account with an EU CCP. The second is a representativeness obligation requiring firms to clear a minimum number of in-scope transactions at an EU CCP each year.
Ashurst reported that ESMA confirmed compliance with the representativeness obligation is assessed on an annual-average basis. At each January and July reporting date, firms must show they met the requirement on average over the preceding 12 months rather than for each individual reference period.
Firms need to track clearing patterns across rolling annual windows, reconstruct activity from 25 June 2025 onward, and validate whether their EU CCP volumes satisfy the representativeness test before the first deadline.
The AAR became applicable in June 2025. ESMA subsequently revised the technical standards to reduce reporting burdens after market feedback, then issued supervisory guidance in early 2026. The publication of templates and instructions now places the regime on a fixed supervisory timetable.
