meta_id 2975302

On 17 March 2026, the European Banking Authority (EBA) published a consultation paper on draft guidelines for the authorisation of initial margin (IM) models under Article 11(3) of the European Market Infrastructure Regulation (EMIR). The guidelines establish a uniform application and authorisation process for financial and non-financial counterparties seeking to use IM models for calculating and exchanging initial margins on non-centrally cleared over-the-counter (OTC) derivative contracts. The draft guidelines address key aspects of the authorisation process, including minimum information requirements for applications, procedures for model changes triggering re-authorisation, and documentation standards. The EBA distinguishes between high-volume institutions counterparties (HVICPs)—credit institutions and investment firms with aggregate average notional amounts exceeding EUR 750 billion—and other counterparties (OCPs) with less significant OTC trading activity. For models based on pro forma models (such as the ISDA Standard Initial Margin Model), the guidelines clarify that competent authorities may only authorise use where the EBA has validated the underlying pro forma model. The guidelines specify that updates constituting fundamental changes to model design, scope of application, or governance arrangements require authorisation. The EBA proposes a phased implementation approach: counterparties with AANA exceeding EUR 2,250 billion must comply from 1 January 2028; those between EUR 750 billion and EUR 2,250 billion from 1 July 2028; and those with AANA between EUR 8 billion and EUR 750 billion from 1 January 2029. The consultation closes on 17 June 2026. Responses should be submitted via the EBA consultation page. The EBA will revise the guidelines based on feedback received, with final publication expected in April 2026.