EBA launches data collection for ISDA SIMM authorisation
11 November 2025 Eurpoe
Image: TensorSpark/stock.adobe.com
The European Banking Authority (EBA) has launched a data collection to obtain the list of EU counterparties that intend to use the International Swaps and Derivatives Association Standard Initial Margin Model (ISDA SIMM), as well as their contact persons.
Firms which are required to request validation of ISDA SIMM by the EBA in line with Article 11(3) of the European Market Infrastructure Regulation (EMIR), in order to carry on using the pro forma model, include:
- Financial and non-financial counterparties that are subject to the requirement to exchange initial margin, in accordance with Article 36 of Commission Delegated Regulation (EU) 2016/2251
- Firms that use — directly or indirectly — the ISDA SIMM pro forma model to comply with such requirement
The EBA highlights the counterparties' obligation to apply for the authorisation of the use of initial margin models, and warns of the legal consequences in case of non-authorised use under EMIR.
The authority states that all financial and non-financial counterparties exchanging initial margins calculated either directly or indirectly using IM models based on ISDA SIMM, should apply to their competent authorities for the authorisation of such models as per EMIR and the EBA’s published on 17 December 2024.
Counterparties must provide their competent authorities with the information requested, which will be used to onboard counterparties onto the EBA’s validation system during the first half of 2026.
This will come ahead of counterparties’ applications to the EBA for validation of ISDA SIMM, which is expected in the second half of 2026. 
Counterparties failing to apply for the EBA’s validation will no longer be permitted to use ISDA SIMM under EMIR until they rectify their status with the EBA.
The EBA’s no-action letter remains in force.
Firms which are required to request validation of ISDA SIMM by the EBA in line with Article 11(3) of the European Market Infrastructure Regulation (EMIR), in order to carry on using the pro forma model, include:
- Financial and non-financial counterparties that are subject to the requirement to exchange initial margin, in accordance with Article 36 of Commission Delegated Regulation (EU) 2016/2251
- Firms that use — directly or indirectly — the ISDA SIMM pro forma model to comply with such requirement
The EBA highlights the counterparties' obligation to apply for the authorisation of the use of initial margin models, and warns of the legal consequences in case of non-authorised use under EMIR.
The authority states that all financial and non-financial counterparties exchanging initial margins calculated either directly or indirectly using IM models based on ISDA SIMM, should apply to their competent authorities for the authorisation of such models as per EMIR and the EBA’s published on 17 December 2024.
Counterparties must provide their competent authorities with the information requested, which will be used to onboard counterparties onto the EBA’s validation system during the first half of 2026.
This will come ahead of counterparties’ applications to the EBA for validation of ISDA SIMM, which is expected in the second half of 2026. 
Counterparties failing to apply for the EBA’s validation will no longer be permitted to use ISDA SIMM under EMIR until they rectify their status with the EBA.
The EBA’s no-action letter remains in force.
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