Jurisdictions across the globe have implemented margin requirements for non-cleared derivatives, largely in line with the standards agreed by the Basel Committee on Banking Supervision (BCBS) and the International Organization of Securities Commissions (IOSCO). Since implementation of the first phase of the requirements in 2016, the US, European Union (EU), Japan and others have extended the requirements in line with the phase-in schedule agreed by BCBS/IOSCO.
Consistency in requirements has enabled ISDA to develop and implement industry solutions to aid compliance, including standard initial margin (IM) and variation margin (VM) documentation, the ISDA Standard Initial Margin Model (ISDA SIMMTM) and ISDA Create – IM, an online tool for negotiating and executing IM documents.
Nonetheless, differences in the implementation across jurisdictions still exist in certain key areas – for example, eligible collateral, settlement time frames and treatment of inter-affiliate transactions. These inconsistencies create unnecessary complexity and costs for derivatives users and contribute to market fragmentation.
This paper highlights the main areas of difference in the implementation of margin requirements for non-cleared derivatives across jurisdictions, and makes recommendations on how to resolve them.
Click on the attached PDF to read the paper.
Documents (1) for Implementation of Margin Requirements and Market Fragmentation
Latest
Response to EC Call for Evidence on Tax Omnibus
On March 30, ISDA, the International Securities Lending Association and the Association for Financial Markets in Europe responded to the European Commission’s (EC) call for evidence on the tax omnibus. The associations argue that inconsistent interpretation of “beneficial ownership” among...
Managing Risk for Australian Superannuation Funds
Assets managed by the Australian superannuation sector reached A$4.5 trillion in December 2025, equivalent to around 160% of Australia’s GDP. Given its size, the sector has rapidly expanded its global footprint, with the share of offshore investments growing as a...
Updated OTC Derivatives Compliance Calendar
ISDA has updated its global calendar of compliance deadlines and regulatory dates for the over-the-counter (OTC) derivatives space.
Next Steps on a Much Improved Basel III Endgame
Publication of the revised Basel III endgame proposal earlier this month marks an important step towards completion of the global capital reforms, giving banks much-needed clarity on the likely calibration of the rules in the US. The new proposal is...