The European Banking Authority is consulting on a new reporting framework to support validation and monitoring of ISDA Standard Initial Margin Model. The consultation runs until November 2, 2026.
The European Banking Authority (EBA) is consulting on a new reporting framework to support the validation and ongoing monitoring of initial margin models based on the ‘Standard Initial Margin Model’ (SIMM) developed by the International Swaps and Derivatives Association (ISDA). The proposed reporting requirements will provide the EBA with the necessary information to perform its role as central validator of pro forma models under EMIR, while ensuring a proportionate approach for reporting entities.
The consultation runs until 2 November 2026.
Since 1 March 2026, the EBA has acted as the central validator of pro forma initial margin models under the European Market Infrastructure Regulation (EMIR). To support this role, the EBA proposes a standardised set of regular reporting requirements for counterparties seeking validation to use ISDA SIMM.
The proposed framework aims to enable the collection of consistent and high-quality information on the use and performance of initial margin models. It will also facilitate the calculation of annual fees related to model validation.
A key feature of the proposal is its focus on proportionality. The scope, content, and frequency of reporting have been designed to provide the EBA and authorities with necessary oversight information while minimizing compliance costs. Firms with less significant OTC trading activities will be subject to lighter reporting requirements, with reports required only once a year.
Comments on the consultation paper can be submitted via the “send your comments” button on the EBA’s consultation page. The deadline for submissions is 2 November 2026.
All comments received will be published after the consultation unless confidentiality is requested.
Following feedback, the EBA plans to adopt a decision by the end of 2026 to establish the data collection process. The first reporting date is expected in December 2027, with data collection starting in the first quarter of 2028.
The new reporting requirements will be included in the EBA technical package version 4.4, Phase 2, with the final version expected in March 2027. Operational arrangements for data collection will be communicated later to entities enrolled in the EBA ISDA SIMM validation system.
Legal background: Regulation (EU) No 648/2012 (EMIR), as amended by Regulation (EU) 2024/2987 (EMIR 3), introduced new requirements for initial margin models for OTC derivatives. Under EMIR Article 11(12a), the EBA is mandated to validate pro forma models, including ISDA SIMM, which became operational on 1 March 2026. This consultation details the information required from counterparties for ongoing validation and monitoring, supporting authorities in supervision and authorization processes.
