The European Supervisory Authorities (ESAs) have rejected the European Commission's proposed amendment to the final draft RTS on risk mitigation techniques for OTC derivatives that are not cleared by a CCP under Article 11(15) of EMIR. Key concerns of the ESAs include: (i) the need for clarity that non-centrally cleared derivatives concluded by CCPs are not covered by EMIR; (ii) the need for clarification of the application of the RTS to transactions concluded with third country counterparties, in particular non-financial counterparties; and (iii) that the calculation of the threshold against non-netting jurisdictions should consider both legacy and new contracts. The ESAs consider that the proposed amendments in each case could lead to unintended consequences. Where the ESAs reject the Commission's amendments, they invite the Commission to restore the original proposals. The ESAs have also requested that some of the points among the Commission's changes that have been made to clarify the RTS be reviewed or improved.