EBA consults on draft guidelines and standards for initial margin model authorisation

The European Banking Authority (EBA) has initiated two public consultations on draft Guidelines and draft Regulatory Technical Standards (RTS) concerning initial margin model authorisation (IMMA) under the European Market Infrastructure Regulation (EMIR). These consultations aim to establish a robust, efficient, and harmonised authorisation process for models used in the exchange of initial margin for non-centrally cleared derivatives across the EU.

The consultation period runs until 17 June 2026. Responses can be submitted via the consultation page by clicking the “send your comments” button. All contributions will be published after the closing date unless confidentiality is requested.

Under EMIR 3, counterparties using internal initial margin models must obtain prior authorisation from their competent authority. The draft Guidelines specify the minimum information and documentation required for applications, building on previous guidance published in December 2024. The draft RTS outline assessment techniques for authorisation, applicable to groups with an aggregate monthly average notional amount exceeding EUR 750 billion in non-centrally cleared OTC derivatives. Models relying on pro-forma models must be validated by the EBA before CA approval.

A public hearing will be held on 4 May 2026, from 10:00 to 12:00 CEST. Registration closes on 30 April 2026, at 16:00 CEST.

The legal framework is based on Regulation (EU) 2024/2987 (EMIR 3), which requires prior authorisation for IM models used as risk mitigation for OTC derivatives not cleared by a central counterparty. The EBA, in cooperation with ESMA and EIOPA, is mandated to issue guidelines to ensure uniform application and supervise validation procedures for these models, especially for firms with a monthly AANA exceeding EUR 750 billion.