domestic clearing capacity for essential euro - denominated clearing services. this would also facilitate rebalancing between domestic and offshore business if, for example, it was deemed more prudent in view of evolving risks in a host ccp. an adequate domestic clearing capacity helps to preserve financial stability within the eu and to ensure the smooth functioning of euro area markets. given the economic benefits of global liquidity pools, implementing the active account will require a carefully calibrated and phased approach. we understand the concerns raised. however, around 50 % of the eu clients that are not active in eu ccps are only active in euro - denominated trades, so crosscurrency pooling is not always the main issue. furthermore, although establishing an active account will not be without cost, it must also be acknowledged that eu stakeholders have a joint responsibility to establish a central clearing framework that is robust in periods of severe stress. disrupted access to critical clearing services during a financial crisis would have much greater financial risk implications than gradually moving part of the respective euro - denominated business to eu ccps. better preparedness for extreme stress events the second area in which further progress is required is our capacity to effectively address low - probability, high - impact types of risk. let me give two examples here. first, the current guidance on non - default loss risk [ 9 ] is much less developed than the guidance on risks related to participant default. this is despite the fact that the impact of non - default losses could be particularly significant, especially given that the resources available to cover such losses – mainly ccps ’ own capital – are limited. this became clear from the results of the fsb, cpmi and iosco analysis of ccp financial resources for recovery and resolution. while ccps are taking significant measures to mitigate non - default loss risk, this risk cannot be eliminated. therefore, arrangements for assessing and preparing for potential non - default losses are essential, and we support the cpmi - iosco initiative to further explore ccps ’ risk mitigants for non - default losses. second, there has been insufficient progress in terms of preparedness for events that, based on historical experience, would go beyond what could be considered extreme but still plausible. progress needs to be made, particularly in conceptualising such scenarios and embedding them in ccp recovery and resolution plans. while it is important to learn from past vulnerabilities – as has typically been the focus to date – we

also need to do more to identify extreme hypothetical scenarios and consider the full range of potential risks, such as financial, conjunctural, geopolitical, cyber and environmental risks. reducing the procyclicality of margins central clearing in turbulent times also raises critical issues in terms of margin procyclicality. a certain degree of margin procyclicality is unavoidable, given that margin requirements reflect evolving risks. at the same time, a certain degree of margin stability over the medium term is necessary to reduce the need for sudden, large margin calls in times of stress. the role of ccps as shock absorbers is crucial in such situations, as they help to avoid negative feedback loops between tightened risk management at ccps and the financial strains of clearing participants. mitigation of margin procyclicality is reflected in both the global standards and the eu rules for ccps. however, recent periods of extreme market volatility have underlined the need to do more. the review conducted in 2020 by the basel committee on banking supervision, cpmi and iosco on margin practices provides us with a clear roadmap for action. [ 13 ] this includes enhancing ccps ’ tools to anticipate stress and reflecting margin procyclicality in the development of countercyclical measures and the validation of margin models. margin transparency should also be enhanced, in terms of both the transparency of ccps vis - a - vis clearing members and the transparency of clearing members vis - a - vis clients. the ecb is actively contributing to the follow - up work that is under way. once the results of this work are available, significant efforts will be needed to embed them in the rules of all relevant jurisdictions. conclusion let me conclude. the introduction of mandatory central clearing has served us well in terms of enhancing counterparty risk management and market transparency. however, in today ’ s turbulent market environment, all stakeholders – ccps, clearing participants and authorities alike – must adopt a more forward - looking mindset. short - term cost considerations – be it stimulating clearing activity in the eu, enhancing stress - testing and cooperative arrangements or stepping up margin requirements and disclosure – must be balanced against the longer - term benefits of a robust set - up in which ccps remain a pillar of our financial system. thank you for your attention. 1. g20 ( 2009 ), “ leaders ’ statement : the pittsburgh summit ”. 2. proposal for a regulation of