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
Latest
Response to FCA on CFI Codes for Transparency
On March 19, ISDA responded to Chapter 3 of the UK Financial Conduct Authority’s (FCA) Quarterly Consultation CP26/8 on transparency requirements for financial instruments under Market Conduct Sourcebook (MAR) 11. Sections 3.11-3.13 of the consultation paper explain a discrepancy between...
Why We Need Safe and Efficient SFT Markets
Securities financing transactions (SFTs) play a vital role in fostering liquidity, mobilizing collateral and supporting the smooth functioning of derivatives markets. But during periods of stress, secured funding markets often come under pressure just when they’re needed most, with reduced...
Response to BoE on Clearing Exemption for PTRR
On March 11, ISDA submitted a response to the Bank of England’s consultation on a proposed approach to exempting post-trade risk reduction (PTRR) transactions from the derivatives clearing obligation under Article 4 of the European Market Infrastructure Regulation (EMIR). ISDA...
IQ Interview with David Bailey
The Bank of England’s Prudential Regulation Authority recently finalized its Basel 3.1 framework for implementation at the start of 2027. David Bailey, executive director for prudential policy, talks to IQ about the importance of global consistency and the need to...