EMIR 3.0 Transforms European Derivatives Market with New Clearing Requirements

A major overhaul of European derivatives regulations took effect in June 2025 when the Active Account Requirement (AAR) under EMIR 3.0 came into force, reshaping how financial institutions clear interest rate derivatives across the continent.

The regulation requires eligible financial counterparties actively trading euro and Polish zloty interest rate derivatives over-the-counter to maintain operational clearing accounts at European central counterparties and process a proportional share of their systemic interest rate trades through these venues. The directive applies to interest rate swaps, overnight indexed swaps, forward rate agreements, and short-term interest rate futures.

The primary goal is to reduce European markets' dependence on non-European clearing houses for instruments denominated in euros and zloty. For Polish financial institutions and international market participants with exposure to zloty trading, the requirement presents both a compliance obligation and a potential path toward improved capital and collateral efficiency.

Eurex Clearing, which launched its over-the-counter interest rate derivatives platform nearly a decade ago, has positioned itself as a significant European alternative to international clearing houses. The venue has developed substantial liquidity pools through partnership programs and competitive offerings. As of late May 2026, Eurex reported average daily trading volumes in OTC interest rate derivatives of 340 billion euros, representing a 31 percent year-on-year increase. Outstanding notional positions reached 55 trillion euros, up 27 percent annually and capturing 23 percent of the euro-denominated market.

Growth has been particularly pronounced in specific instrument categories. Interest rate swap volumes climbed 124 percent year-on-year to 65 billion euros in average daily trading, while overnight indexed swap volumes surged 193 percent to 82 billion euros daily.

The clearing venue provides market participants with multiple trading protocols, including request-for-quote and streaming services through major platforms, as well as central limit order book functionality. Buy-side institutions now represent 89 percent of total dollar-value-of-one-basis-point positions across the platform, with over 2,500 registered legal entities.

Beyond euro-denominated instruments, Eurex has expanded into Polish zloty derivatives clearing. In November 2025, twelve major international banks executed their first trades in zloty-denominated interest rate swaps and forward rate agreements on the platform. The offering now includes clearing services for both WIBOR-referenced instruments and POLSTR, Poland's new overnight risk-free rate benchmark. Eurex has introduced market-making schemes and coordinated with trading platforms to enhance liquidity access.

A significant commercial advantage for market participants choosing Eurex involves portfolio-level efficiency. The platform uses its PRISMA margining methodology to calculate collateral requirements across multiple instruments cleared at the same venue, enabling offsets that can reduce overall capital requirements for active traders.