The European Banking Authority (EBA) launched a public consultation on the fees that financial and non-financial counterparties would pay for EBA validation of pro forma models under the European Market Infrastructure Regulation (EMIR). The proposal would introduce an annual fee per validated pro forma model, reflecting the EBA’s new role as the EU central validator. Pro forma models such as ISDA SIMM are used by industry to calculate initial margin. The discussion paper sets out the EBA’s budgeting approach and estimated costs for performing the validation function, proposes methods for calculating the fees, and covers practical aspects including payment modalities. The consultation supports the EBA’s response to the European Commission’s call for advice on a possible Delegated Act specifying the method for determining these fees, with that response due by Q2 2025. The consultation is open until 7 April 2025, after which contributions will be published unless respondents request otherwise.
European Banking Authority 2025-03-05
European Banking Authority consults on annual fees for EU-wide validation of EMIR pro forma initial margin models
The European Banking Authority (EBA) has initiated a public consultation on fees for validating pro forma models under the European Market Infrastructure Regulation (EMIR). The proposal includes an annual fee per validated model, aligning with the EBA's role as the EU central validator. The consultation outlines budgeting, cost estimates, fee calculation methods, and payment modalities, supporting the EBA's advice to the European Commission on a Delegated Act.