The European Banking Authority launched public consultations on draft guidelines and technical standards for initial margin model authorisation under EMIR 3, open until 17 June 2026.
The European Banking Authority (EBA) has launched two public consultations on draft Guidelines and draft Regulatory Technical Standards (RTS) regarding initial margin model authorisation (IMMA) under the European Market Infrastructure Regulation (EMIR). These consultations aim to establish a robust, efficient, and harmonised authorisation process for models used in the exchange of initial margin for non-centrally cleared derivatives across the EU.
The consultations run until 17 June 2026. Under EMIR 3, counterparties using internal initial margin models must obtain prior authorisation from their competent authority (CA). The draft Guidelines specify the minimum information and documentation required for application, building on previous guidance published in December 2024. The draft RTS outline assessment techniques that CAs will apply during authorisation, applicable to groups with an average monthly notional amount exceeding EUR 750 billion in non-centrally cleared OTC derivatives.
Where an internal model relies on a pro-forma model, it must be validated by the EBA before CA approval. Responses to the consultation can be submitted via the consultation page, with all contributions published unless confidentiality is requested. A public hearing will be held on 4 May 2026 from 10:00 to 12:00 CEST, with registration closing on 30 April 2026 at 16:00 CEST.
The legal basis for these measures is Regulation (EU) 2024/2987 (EMIR 3), which requires prior authorisation for IM models used as risk mitigation for OTC derivatives not cleared by a central counterparty. The EBA, in cooperation with ESMA and EIOPA, is empowered to issue guidelines and establish supervisory procedures for validation of these models, covering firms with a monthly AANA exceeding EUR 750 billion, as detailed in the technical standards developed by the ESAs.
