EBA consults on reporting framework for ISDA’s SIMM
10 August 2026 Europe
Image: Rezmin/stock.adobe.com
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 International Swaps and Derivatives Association’s (ISDA) Standard Initial Margin Model (SIMM).
The proposed reporting requirements will give the EBA the necessary information to act as the central validator of pro forma models under the European Market Infrastructure Regulation (EMIR), while maintaining a proportionate approach for reporting firms.
The consultation runs until 2 November 2026.
​Since 1 March 2026, EBA has acted as the central validator of pro forma initial margin models under EMIR.
To support this role, EBA is proposing a standardised set of regular reporting requirements for counterparties seeking validation to use ISDA’s SIMM.
The proposed framework would allow the EBA to collect consistent, high‑quality data on the use and performance of initial margin models.
Additionally, it would provide the information needed to calculate the annual fees associated with the validation of pro forma models.
In line with the EBA’s push to streamline regulatory oversight, firms with limited OTC activity would face significantly lighter reporting requirements, says the authority, with reporting required only once a year.
After considering the feedback received during the consultation, the EBA intends to adopt a decision by the end of 2026.
The first reporting reference date is expected to be December 2027 with data to be collected in the first quarter of 2028.
The proposed reporting requirements will give the EBA the necessary information to act as the central validator of pro forma models under the European Market Infrastructure Regulation (EMIR), while maintaining a proportionate approach for reporting firms.
The consultation runs until 2 November 2026.
​Since 1 March 2026, EBA has acted as the central validator of pro forma initial margin models under EMIR.
To support this role, EBA is proposing a standardised set of regular reporting requirements for counterparties seeking validation to use ISDA’s SIMM.
The proposed framework would allow the EBA to collect consistent, high‑quality data on the use and performance of initial margin models.
Additionally, it would provide the information needed to calculate the annual fees associated with the validation of pro forma models.
In line with the EBA’s push to streamline regulatory oversight, firms with limited OTC activity would face significantly lighter reporting requirements, says the authority, with reporting required only once a year.
After considering the feedback received during the consultation, the EBA intends to adopt a decision by the end of 2026.
The first reporting reference date is expected to be December 2027 with data to be collected in the first quarter of 2028.
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