EBA consults on regulatory products on initial margin model
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EBA consults on regulatory products on initial margin model 18 March 2026Europe Reporter: Hansa Tote
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The European Banking Authority (EBA) has launched two public consultations on draft Guidelines and draft Regulatory Technical Standards (RTS) on Initial Margin Model Authorisation (IMMA) under the European Market Infrastructure Regulation (EMIR).
According to the EBA, these consultations mark an important step in ensuring that models used for the exchange of initial margin for non-centrally cleared derivatives are subject to a robust, efficient, and harmonised authorisation process across the EU.
The consultations will run until 17 June 2026.
Under the new EMIR 3 rules, counterparties using internal margin models must obtain prior authorisation from their competent authority.
The two regulatory products published by the ECB aim to support a transparent, predictable, and consistent approach to model assessment and authorisation throughout the EU.
The draft Guidelines detail the minimum information and documentation that counterparties must submit for their application to be considered complete.
These requirements build upon the information already outlined in the Annex to the EBA’s No Action Letter on the application of EMIR, published in December 2024, which will no longer apply once the new Guidelines come into force.
The Draft RTS set out the assessment techniques that competent authorities will apply when authorising initial margin models.
The techniques only apply to counterparties belonging to groups with an aggregate monthly average notional amount (AANA) of non-centrally cleared OTC derivatives exceeding €750 billion.
Where an internal model relies on a pro-forma model, it must be validated by the EBA prior to authorisation by the competent authority.
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