Critical infrastructure (CCPs): political accountability and the policy effects of EMIR

Central counterparties (CCPs) constitute an important nerve system of the international financial markets. With their growing importance, the regulation of CCPs at the international, European and national levels became more and more dense. In order to allow holding multiple types of regulators accountable, a multitude of centralized, decentralized or even fragmented accountability channels were created. European political actors have sought to contain decentralization and fragmentation in order ensure that the use of accountability channels contributes to improving regulation and prevents regulatory venue shopping. The use of the accountability mechanisms is of particular importance if redistributive issues are at stake. The latter create conflicts between winners and losers of a regulation such as in the case of an unlevelled playing field between member state CCPs and third country CCPs, and in the case of a possible failure of CCPs and their recovery or resolution between financial firms and tax payers.