Are All CDS Contracts Required to Be Centrally Cleared?
No, not all CDS contracts are required to be centrally cleared, although regulations since the 2008 financial crisis, like the Dodd-Frank Act in the US, mandate it for a large portion of the market. Specifically, standardized CDS contracts between financial entities are generally subject to mandatory clearing.
However, exemptions exist for certain types of contracts, such as highly customized or bespoke CDS trades. Additionally, trades where one of the counterparties is a non-financial "end-user" (e.g. a corporation hedging commercial risk) are often exempt from the clearing requirement.