Initial Margin for Non-Centrally Cleared Derivatives: Issues for 2019 and 2020

In response to the global financial crisis of 2008-2009, the Group of 20 nations agreed to a financial regulatory reform agenda covering the over-the-counter derivatives markets and market participants, among them recommendations for the implementation of margin requirements for non-centrally cleared derivatives. The Basel Committee on Bank Supervision and International Organization of Securities Commissions subsequently developed and finalized their Final Framework on Margin Requirements for Non-Centrally Cleared Derivatives, which sought to establish international standards for such requirements, to be phased in over time. 

As agreed in the revised implementation timeline to the final framework, the uncleared margin rules (UMR) began to be phased-in on September 1, 2016 for the largest market participants.  Broader implementation of variation margin (VM) requirements occurred in March 2017, while initial margin (IM) requirements continue to phase-in annually through 2020.

The final phases of the UMR will occur on September 1 of 2019 and 2020, when a large number of additional counterparties will be brought into scope for IM requirements. The fundamental challenges for market participants during the final phases of IM implementation are distinct from and more intense than those experienced in previous phases, and therefore likely to result in broader systemic impact. 

In this paper, ISDA and the Securities Industry and Financial Markets Association (SIFMA) seek to highlight the significant challenges market participants will encounter during the final phases of IM implementation and identify the key tasks and resulting hurdles that must be overcome to ensure an orderly implementation that avoids disruption to the functioning of the derivatives market. 

 

Documents (1) for Initial Margin for Non-Centrally Cleared Derivatives: Issues for 2019 and 2020

Response to JSCC on Clearing Fund Consolidation

On August 12, ISDA responded to the Japan Securities Clearing Corporation’s (JSCC) consultation on its proposal to consolidate clearing fund consumption, calculation and deposit segmentation across six clearing qualifications under the Financial Instruments and Exchange Act. ISDA members broadly support...

Response on CSDD Guidelines

On August 6, ISDA responded to the European Commission’s (EC) consultation on due diligence guidelines under the Corporate Sustainability Due Diligence Directive (CSDDD). While ISDA acknowledges that model contractual clauses can be a helpful resource for in-scope companies, there are...

SwapsInfo H1 2026 & Q2 2026 Review

Trading activity in interest rate derivatives (IRD) and credit derivatives increased in the first half of 2026 compared with the same period in 2025. Growth in IRD was driven by overnight index swaps (OIS), while higher index credit derivatives activity...