ISDA stresses the need to have clear Implementing Regulations in place as soon as possible, to facilitate the transition or alternative arrangements, in particular for complex contracts.

This is a recurring theme across jurisdictions, with a risk that legal disputes will derail a smooth transition.

See the European Commission publication here – https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13120-Interest-rates-Statutory-replacement-rate-for-the-EONIA-benchmark_en

See the ISDA response here – https://www.isda.org/a/1HTgE/ISDA-Responds-to-EC-on-EONIA.pdf