EU EMIR: Expected timelines for EMIR 3 AAR and Article 7d reporting

On 11 December 2025, the European Securities and Markets Authority (ESMA) published a statement on upcoming reporting obligations under EMIR 3.

ESMA’s statement concerns two new reporting obligations introduced by EMIR 3: (1) the reporting obligation associated with the active account requirement (AAR) (AAR reporting); and (2) the reporting obligation relating to clearing activity at recognised third-country central counterparties (CCPs) (Article 7d reporting).

In summary, the statement clarifies that ESMA expects:

• entities subject to the AAR will provide their first AAR reporting submission by July 2026 (this first submission should include any backlog data demonstrating compliance with the AAR for the period starting 25 June 2025, along with data for 2026); and
• the first Article 7d reporting on 2025 data will be submitted together with the 2026 reporting cycle, following the implementation of the necessary Level 2 measures.

The regulatory technical standards specifying the AAR conditions (AAR RTS), including details on AAR reporting, were adopted by the European Commission on 29 October 2025 and are currently under scrutiny by the European Parliament and Council. ESMA has indicated that it will also develop additional instructions on how to report according to the templates included in the AAR RTS. This is something to monitor developments on in early 2026.

The content and details of the Article 7d reporting will also be set out in technical standards, and further developments are expected in 2026.

Please feel free to contact us if you would like to discuss this, or any other aspect of EMIR 3.