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G20 members have committed to limit systemic risk in the financial system after the financial crisis of 2007/08. In the EU, this is implemented through the European Market Infrastructure Regulation (EMIR) 1 , which came into force in 2012. EMIR specifies the obligations to central clearing, reporting, risk mitigation and bilateral margining for over-the-counter (OTC) derivative contracts. The clearing thresholds set in 2012 are currently under review by the European Securities and Market Authority (ESMA). Energy Traders Europe (EFET) has commissioned Frontier Economics (supported by Luther Lawfirm) to produce a study on the review of the commodity clearing threshold (CCT) in order to substantiate its members’ position as utilities and energy traders which almost all are non-financial counterparties (NFCs) on a scientific basis. This study also captures insights and practical case studies from a multitude of bilateral interviews with Energy Traders Europe members and affiliates.