This response emphasises that CCP participation requirements should not result in CCPs duplicating prudential supervision, DORA enforcement, or wider legal and regulatory oversight that already sits with competent authorities, as this would create unnecessary operational burden without clear risk management benefit. Instead, it argues that admission criteria should focus squarely on the practical outcome of whether a clearing member can reliably meet its obligations to the CCP, including under stress, using an outcomes-based and risk-focused approach. Throughout, the response advocates proportionality, stressing that CCPs must retain flexibility to calibrate requirements across different types of clearing members, client clearing models, and NFC participation, to support fair and open access while maintaining robust risk management.

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