FIA has published a paper outlining industry perspectives on operational capacity and stress testing in relation to the AAR in EMIR 3.0. In the paper, produced by the FIA EMIR 3.0 WG, we explore practical implementation challenges for market participants subject to the AAR requirement, specifically concerning confirmation of operational capacity, stress testing of operational conditions and associated reporting requirements. We note that each clearing firm is set up differently, uses different systems that connect it to CCPs and clients, and has different existing stress testing practices, so implementation of the operational aspects of the AAR will differ among clearing firms.

Notwithstanding these differences, FIA clearing members understand that stress testing of the AAR operational conditions can be met by clearing firms without needing to involve the CCPs, although the clearing member and the CCP may agree bilaterally that they wish to partner in the stress testing exercise. Stress testing of the operational conditions by the clearing firm will be conducted on behalf of AAR clients and will not be client specific. It also does not need to involve any financial information, such as prices, margin, etc.

The paper also discusses the reporting obligation with respect to operational capacity and stress-testing where we note an inconsistency between the ESMA statement on the EMIR AAR reporting obligations from December 2025 and the AAR RTS when it comes to the submission deadline for first reports under EMIR Article 7b and the reporting period.   

Together with the operational capacity and stress testing industry paper, FIA has also published four template statements to help in-scope firms comply with AAR RTS Article 2(1)(e) regarding operational capacity confirmation. The four written statement templates cover the following scenarios:

-Clearing member statement to its national competent authority confirming operational capacity where the clearing member is subject to AAR;

-Clearing service provider statement to its AAR clients confirming operational capacity;

-AAR client statement to its national competent authority confirming that its clearing service provider meets the operational capacity requirements (where the client uses only one clearing service provider); and

-AAR client statement to its national competent authority confirming that its clearing service providers meet the operational capacity requirements (where the client uses two or more clearing service providers).

The template statements are currently in draft form until publication of the AAR RTS in the Official Journal (OJ) of the EU. After publication of the AAR RTS in the OJ of the EU, they will be available for use by all market participants subject to complying with the disclaimer and copyright statement in each of the template documents.

Written Statement                                                  Templates		Word   (only final                       versions following   publication of   the   AAR   RTS in the   OJ   will be   published in Word)	PDF      (currently in draft                form)
CM House Version	Clearing member statement   to its national competent   authority confirming   operational capacity where   the clearing member is   subject to AAR		PDF
CSP Version                                 (generic)	Clearing service provider   statement to its AAR clients   confirming operational   capacity		PDF
Client version with a                  single CSP	AAR client statement to its   national competent authority   confirming that its clearing   service provider meets the   operational capacity   requirements (where the   client uses only one clearing   service provider)		PDF
Client version with                      multiple CSPs	AAR client statement to its   national competent authority   confirming that its clearing   service providers meet the   operational capacity   requirements (where the   client uses two or more   clearing service providers)		PDF