Each September until 2022*, increasing numbers of entities will be required to meet initial margin regulations as the threshold level for compliance reduces. Preparation for meeting these requirements will take significant time, and will involve intensive work to ensure systems, processes and documentation are in place.
ISDA has published a fact sheet that sets out the steps firms should take when preparing to comply with regulatory initial margin requirements. These are not necessarily presented in chronological order – the precise order and timing will depend on a firm’s specific circumstances.
STEP 1: Identify in-scope entities early
STEP 2: Make early disclosures to counterparties
STEP 3: Exchange information on compliance
STEP 4: Identify special cases
STEP 5: Establish custodial relationships
STEP 6: Prepare for compliance
STEP 7: Negotiate/execute documentation
STEP 8: Finalize preparations
- Updated in August 2020 to account for new Basel Committee on Banking Supervision/IOSCO implementation schedule.
Click on the attached PDF to read the full list of steps.
Documents (1) for Getting Ready for Initial Margin: The Steps to Take
Latest
CDS Market Dynamics: Record 2025
Global credit default swap (CDS) market activity reached a record $41.8 trillion in 2025, surpassing the previous peak of $38.7 trillion in 2022. Index CDS drove the increase, accounting for 93.3% of total activity and reaching a record $39.0 trillion....
ISDA Letter to CFTC on Public Interest Determinations for Event Contracts
On July 27, ISDA submitted a letter to the U.S. Commodity Futures Trading Commission (CFTC) on the CFTC’s proposed rulemaking on public interest determinations for event contracts published in the Federal Register on June 12, 2026. ISDA emphasized the importance...
ISDA Letter to BCBS on RMA Models
On July 24, ISDA wrote to the Basel Committee on Banking Supervision (BCBS) to request guidance on how the proposed Risk Mitigation Accounting (RMA) model under International Financial Reporting Standard (IFRS) 9/IFRS 7 should be treated for prudential regulatory capital...
US Treasury Repo Clearing Indicators June 2026
The ISDA-Actrix US Treasury Repo Market Clearing Indicators illustrate central clearing adoption in the US Treasury repo market. Sponsored cleared repo volumes are used as a proxy to monitor client participation in central clearing, a key objective of the Securities...