EU financial and non-financial EU counterparties exchanging IM based on ISDA SIMM^® should have already submitted an initial application for authorisation to their competent authority (CA), and ECB if applicable. If not, they should do so timely to ensure continued use of SIMM.

Until an EU counterparty becomes subject to CA authorisation, the data in the pro-forma model application to CA/ECB should be updated annually by the end of March each year. Therefore, counterparties which have already submitted an initial application for the use of SIMM should submit an updated application by March 31, 2026, using a 2025 AANA figure and IM amounts based on SIMM 2.8+2506.

ISDA is providing guidance to ISDA SIMM^® users to promote awareness and facilitate a consistent approach to preparing data their initial and updated applications. At the request of SIMM users, ISDA has also developed a generic template for the initial and updated application. Use of the template is optional and at the discretion of each applying entity. A timeline for EU SIMM validation and authorisation is also provided. These documents are subject to change.

Questions may be directed to isdasimmtechsupport@isda.org

ISDA EU EMIR IM Model Application Guidance

ISDA EU EMIR IM Model Application Template

EU SIMM Validation and Authorisation Timeline