IOSCO Is Raising the Bar on Commodity Derivatives Oversight. Are You Ready?

IOSCO Commodity Derivatives Checklist

In March 2026, IOSCO launched a consultation (News Release 787) setting out good practices for commodity derivatives markets, with particular focus on OTC positions. IOSCO's standards aren't directly binding, but they're highly influential - they typically shape how national regulators, including the FCA and ESMA, set supervisory expectations over the following two to five years.

The direction is clear: greater transparency over OTC and exchange-traded positions, more proactive surveillance of large positions and concentration risk, stronger governance, and joined-up oversight across jurisdictions. IOSCO's own reviews found that even regulators struggle to access complete OTC data - which tells you how far most firms still have to go. This practical checklist walks through the ten areas regulators will expect you to have covered, so you can benchmark where you stand today and where the real gaps sit before they're tested in a live regulatory conversation.

This checklist is for compliance, risk, financial crime, surveillance and governance leaders at banks, insurers, pension schemes, hedge funds, asset and wealth managers, e-money and payment firms, and other FCA-regulated businesses trading commodity derivatives -OTC, exchange-traded, or both. If your firm carries positions, hedges exposure, or acts as an intermediary in these markets, IOSCO's direction of travel applies to you.

Download it to assess:

Understand Your Exposure — whether you have a complete, aggregated view of your commodity derivatives activity — across OTC and exchange-traded positions, desks, entities and jurisdictions — and know exactly where your largest exposures sit.

Data & Transparency — whether your trading data is complete, accurate and timely enough to reconcile OTC against exchange-traded positions and produce regulator-ready reports on demand.

Risk Monitoring and Surveillance — whether your monitoring is forward-looking rather than retrospective, with clear thresholds and triggers for escalating large positions, concentration risk and market impact.

Governance & Accountability — whether ownership of commodity derivatives risk is clear, and whether decisions on large or complex positions are documented, justified and defensible.

Scenario Analysis & Stress Testing — whether you test severe but plausible market scenarios and use the results in real decision-making, not just reporting.

Cross-Border Coordination — whether you have a consistent global view of exposures and can respond to multiple regulators with one coherent position.

Control & Escalation — whether controls over trade capture, position reporting and limit monitoring actually catch issues, and whether escalation for breaches and data gaps is clear and fast.

Technology and Infrastructure — whether your systems give real-time visibility and integration across platforms, or whether you're still relying on manual spreadsheets and fragmented systems.

Regulatory Readiness — whether you can demonstrate full visibility, strong governance and effective monitoring to regulators like the FCA or ESMA, with evidence, not just policies.

Senior Management Oversight — whether senior management receives clear, actionable MI on emerging risk and concentrations, and whether decisions are timely, informed and properly challenged.

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