Central Bank of Ireland publishes Markets Update No 8 of 2025

On 11 December, the Central Bank of Ireland (the Central Bank) published Issue No 8 2025 of its regular Market Update, in which it sets out alerts of interest to Irish regulated firms and other market participants. For our summaries of the previous issues, please see the right-hand column of this page.

The new update contains a single item:

Postponement of EMIR 3.0 December reporting

On 11 December 2025, the European Securities and Markets Authority (ESMA) issued a public statement providing clarifications on two key reporting obligations introduced by EMIR 3.0 (i.e. Regulation (EU) 2024/2987):

• Reporting under the Active Account Requirement (AAR)

• Reporting of information on clearing activity at recognised Third-Country CCPs (Article 7d of EMIR)

The Central Bank's update focusses on the second of these reporting obligations.

Under Article 7d of EMIR 3.0, clearing members and clients are subject to a new reporting obligation in relation to their clearing activities at recognised Third-Country CCPs, whereby they are expected to report to their competent authorities annually.

The content and format of these reports will be specified by ESMA through Level 2 regulatory technical standards and implementing technical standards. Since these standards have not yet been published, ESMA has clarified that the first reporting under Article 7d of EMIR on 2025 data will be submitted together with the 2026 reporting cycle following the implementation of the necessary Level 2 measures.

The Central Bank will align its expectations with ESMA and the other EU National Competent Authorities.