EBA - Public consultations on draft Guidelines and draft RTS on initial margin model authorisation under EMIR
The draft Guidelines specify the minimum information and documentation that counterparties must submit for their application to be considered complete. These requirements build on the information already outlined in the Annex to the EBA’s No Action Letter on the application of EMIR, published in December 2024, which will cease to apply once the new Guidelines enter into force.
The draft RTS set out the assessment techniques that CAs will apply when authorising initial margin models. They only apply to counterparties belonging to groups with an aggregate monthly average notional amount (AANA) of non-centrally cleared over-the-counter (OTC) derivatives exceeding EUR 750 billion. Where an internal model relies on a pro-forma model, it must be validated by the EBA prior to authorisation by the CA.
The deadline for the submission of comments is 17 June 2026.
