The European Banking Authority has opened two public consultations on draft Guidelines and draft Regulatory Technical Standards (RTS) covering the EU authorisation process for internal initial margin models used for non-centrally cleared derivatives under the European Market Infrastructure Regulation (EMIR 3). The package is intended to support a robust and harmonised approach to model assessment and authorisation across EU competent authorities. The draft Guidelines specify the minimum information and documentation that counterparties must submit for an initial margin model authorisation application to be treated as complete, building on information previously set out in the annex to the EBA’s December 2024 No Action Letter, which will cease to apply once the Guidelines enter into force. The draft RTS set out assessment techniques for competent authorities and apply only to counterparties in groups with an aggregate monthly average notional amount (AANA) of non-centrally cleared over-the-counter derivatives exceeding EUR 750 billion; where an internal model relies on a pro-forma model, EBA validation is required before authorisation by the competent authority. Comments are requested by 17 June 2026. A public hearing is scheduled for 4 May 2026 (10:00–12:00 CEST), with registration closing on 30 April 2026 at 16:00 CEST.
European Banking Authority 2026-03-17
European Banking Authority launches consultations on EMIR 3 initial margin model authorisation rules for groups above EUR 750 billion AANA
The European Banking Authority has launched consultations on draft Guidelines and Regulatory Technical Standards for the EU authorisation process of internal initial margin models under EMIR 3. The Guidelines outline required documentation for application completeness, while the RTS detail assessment techniques for authorities, applicable to counterparties with an AANA exceeding EUR 750 billion.