EBA to begin EU validation of ISDA SIMM from March 2026

The European Banking Authority (EBA) will commence the central validation of the International Swaps and Derivatives Association Standard Initial Margin Model (ISDA SIMM) on 1 March 2026.

The Decision on arrangements for ISDA SIMM validation, published today, outlines the operational framework for the validation function, including onboarding, application procedures, governance, cooperation mechanisms with authorities and ISDA, and criteria for monitoring model changes.

This initiative is part of the EBA’s role under the amended European Market Infrastructure Regulation (EMIR) to ensure consistent, robust, and transparent supervisory oversight of initial margin models used for non-centrally cleared OTC derivatives.

The EBA confirms that its validation function is operational and ready to start on 1 March 2026. The related Decision on arrangements for IMMV of ISDA SIMM also enters into force on this date.

In accordance with EMIR, the EBA has collected data from counterparties exchanging initial margin using ISDA SIMM. The onboarding process will occur in stages, beginning with direct contact with counterparties, followed by a validation application phase starting in August 2026.

Legal basis: Article 11(12a) and Article 89(13) of EMIR. The EBA will publicly announce the setup of its validation function as mandated.