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# ESMA Q\&A 2777 — Q\&A — AAR representativeness obligation \[Answer Published]

*Answer Published · ESMA publication · Checked against the ESMA publication on 11 Oct 2026 ·* [*Official source*](https://www.esma.europa.eu/publications-data/questions-answers/2777)

|                         |                                                                               |
| ----------------------- | ----------------------------------------------------------------------------- |
| **Full title**          | ESMA Q\&A 2777 — Q\&A — AAR representativeness obligation \[Answer Published] |
| **Issuer**              | ESMA                                                                          |
| **Reference**           | ESMA\_QA\_2777                                                                |
| **Document type**       | Q\&A                                                                          |
| **Date**                | published 16/02/2026; answer 27-02-2026                                       |
| **Addressees**          | Not recorded                                                                  |
| **Legal basis**         | Article 7a                                                                    |
| **Related instruments** | None recorded                                                                 |
| **Text on this page**   | Word for word — the full text of the ESMA publication                         |

**AAR representativeness obligation**

#### Question

When and how should a counterparty comply with the representativeness obligation and subsequent reporting when it reaches the EUR 6 billion threshold for the first time?

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#### Answer

Counterparties must monitor their positions on a continuous basis against the relevant thresholds. Therefore, a counterparty subject to the AAR becomes subject to the representativeness obligation as soon as it reaches the EUR 6 billion threshold in the relevant categories referred to in Article 7a(6) of EMIR.

As a result, the first reporting is expected to be submitted at the next reporting date (either January or July, whichever is sooner).

However, it is recognised that full compliance with the representativeness obligation (i.e. clearing 5 trades on a yearly average in the account) can only be demonstrated once a complete year has passed.

***