Jurisdictions across the globe have implemented margin requirements for non-cleared derivatives, largely in line with the standards agreed by the Basel Committee on Banking Supervision (BCBS) and the International Organization of Securities Commissions (IOSCO). Since implementation of the first phase of the requirements in 2016, the US, European Union (EU), Japan and others have extended the requirements in line with the phase-in schedule agreed by BCBS/IOSCO.
Consistency in requirements has enabled ISDA to develop and implement industry solutions to aid compliance, including standard initial margin (IM) and variation margin (VM) documentation, the ISDA Standard Initial Margin Model (ISDA SIMMTM) and ISDA Create – IM, an online tool for negotiating and executing IM documents.
Nonetheless, differences in the implementation across jurisdictions still exist in certain key areas – for example, eligible collateral, settlement time frames and treatment of inter-affiliate transactions. These inconsistencies create unnecessary complexity and costs for derivatives users and contribute to market fragmentation.
This paper highlights the main areas of difference in the implementation of margin requirements for non-cleared derivatives across jurisdictions, and makes recommendations on how to resolve them.
Click on the attached PDF to read the paper.
Documents (1) for Implementation of Margin Requirements and Market Fragmentation
Latest
Market Transformation – IQ May 2026
On the 250th anniversary of American independence, this year’s ISDA Annual General Meeting (AGM) was held in Boston, a city that played a prominent role in the American Revolution. In his opening remarks, ISDA chief executive Scott O’Malia drew a...
Updated OTC Derivatives Compliance Calendar
ISDA has updated its global calendar of compliance deadlines and regulatory dates for the over-the-counter (OTC) derivatives space.
Letter to EC and ESMA on Derivatives Framework
On March 27, ISDA sent a letter to the European Commission (EC) and the European Securities and Markets Authority (ESMA) to highlight several technical issues arising from the interaction between the delegated regulation (EU) 2025/1003 on identifying reference data to...
Response on Proposed Changes to Transaction Rules
On May 22, ISDA and the Global Foreign Exchange Division (GFXD) of the Global Financial Markets Association submitted a joint response to the Australian Securities and Investments Commission's (ASIC) consultation on proposed changes to the ASIC Derivative Transaction Rules (Reporting)...
