Active Account Requirement reporting deadline set
De Nederlandsche Bank (DNB) and the Authority for the Financial Markets (AFM) have issued a joint newsletter on the first reporting under the Active Account Requirement (AAR) of EMIR 3. Institutions must submit their initial report by July 31, 2026, covering compliance from June 2025.
New EMIR 3 rules in force
The Regulatory Technical Standards (RTS) for the Active Account Requirement (AAR), a component of the revised European Market Infrastructure Regulation (EMIR 3), were published on February 6, 2026, and entered into force on February 26. These RTS specify the operational, representativeness, and reporting obligations arising from Articles 7a and 7b of EMIR 3. Institutions subject to the clearing obligation and meeting the conditions set out in Article 7a(1) of EMIR 3 are expected to submit their first AAR report by July 31, 2026.
This report should cover the period from June 25, 2025, to June 30, 2026, providing insight into compliance with the AAR over that period.
Guidance and submission details
ESMA published additional guidance on the representativeness obligation on February 20, 2026.
This guidance clarifies how institutions should determine the "most relevant subcategories" of derivatives, assess compliance with the representativeness requirement, and correctly complete related reporting templates.
Although the reporting tables set out in the RTS are not yet formally in force for this first reporting, DNB and AFM strongly encourage institutions to use the provided templates for uniform data processing.
Reports can be submitted in July via DNB's existing reporting portal or by email to AFM, preferably in CSV format.
Institutions with questions should contact their account supervisor for support.