The EBA Consults On Reporting Framework For Validation And Monitoring Of ISDA Standard Initial Margin Model

​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 is proposing a standardised set of regular reporting requirements for counterparties seeking validation to use ISDA SIMM.

​The proposed framework would enable the collection of consistent and high-quality information on the use and performance of initial margin models. It would also provide the information needed to calculate the annual fees associated with the validation of pro forma models.

​A key feature of the proposal is its strong focus on proportionality. The scope, content and frequency of the reporting requirements have been carefully designed to provide the EBA and competent authorities with the information necessary for effective oversight, while minimising the cost of compliance for reporting entities. In line with the EBA’s efforts to improve the efficiency of the regulatory and supervisory framework, firms with less significant OTC trading activities would be subject to substantially lighter reporting requirements, with reporting required only once a year.​

Consultation process

Comments to the consultation paper can be sent by clicking on the “send your comments” button on the EBA's consultation page. The deadline for the submission of comments is 2 November 2026.

All comments received will be published following the end of the public consultation, unless requested otherwise.

Next steps

After considering the feedback received during the consultation, the EBA intends to adopt a Decision by the end of 2026 establishing the collection of the relevant information.

The first reporting reference date is expected to be December 2027 and data to be collected in the first quarter of 2028.

The new reporting requirements will be incorporated into the EBA technical package version 4.4, Phase 2. The final technical package is expected to be released in March 2027.

The EBA will collect the information directly from reporting entities. Operational arrangements for the data collection process will be communicated at a later stage to the entities onboarded onto the EBA ISDA SIMM validation system. 

Legal basis and background information

Regulation (EU) No 648/2012 (EMIR), as amended by Regulation (EU) 2024/2987 (EMIR 3), introduced new requirements for the models used to calculate initial margin for non-centrally cleared OTC derivative contracts.

Under Article 11(12a) of EMIR, the EBA is mandated to centrally validate the elements and general aspects of pro forma models used by financial counterparties and non-financial counterparties subject to initial margin requirements. The ISDA SIMM qualifies as a pro forma model within the meaning of Article 11(12a) of EMIR.

The EBA's central validation function became operational on 1 March 2026.

This consultation paper sets out the information that counterparties seeking validation for the use of ISDA SIMM would be required to submit on a regular basis. The information is intended to enable the EBA to validate the model and monitor its performance on an ongoing basis, in accordance with the EBA Decision on arrangements for the Initial Margin Model Validation function under EMIR (EBA/DC/610) and the related Delegated Act on fees. It will also support competent authorities in their authorisation and supervision of the use of initial margin models based on ISDA SIMM.