ISDA SIMM v2.8+2506 goes into effect on December 6, 2025. An initial application to the relevant competent authority is required by this date to ensure continued use by of ISDA SIMM® by financial and non-financial EU counterparties exchanging IM. As affirmed with the EBA, if an EU counterparty already submitted an initial application to its competent authority based on SIMM v2.7+2412, they do not need to resubmit because they are transitioning to SIMM v2.8+2506.
ISDA is providing guidance to ISDA SIMM® users to promote awareness and facilitate a consistent approach to preparing data for the initial application. At the request of SIMM users, ISDA has also developed a generic template for the initial application. Use of the template is optional and at the discretion of each applying entity. Questions may be directed to isdasimmtechsupport@isda.org
ISDA EU EMIR IM Model Application Guidance
ISDA EU EMIR IM Model Application Template
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