European Banking Authority Survey for Entities in Scope of Initial Margin Model Authorization Regime under EMIR 3

The European Banking Authority has launched, in cooperation with the European Securities and Markets Authority and the European Insurance and Occupational Pensions Authority, a survey addressed to entities within the scope of the initial margin model authorization regime introduced by the European Market Infrastructure Regulation 3.

EMIR 3 will introduce new requirements such as: (i) an authorization regime for IM models used by counterparties in the EU; (ii) a new EBA central validation function for pro-forma margin models; and (iii) a supervision of IM models with greater focus on larger counterparties. The survey is seeking general information on entities within the scope of IM model authorization, as well as specific information relevant for fee calculation and on initial margins and IM models used. The information gathered will guide the EBA in the setup of its central validation function and inform the EBA's response to the European Commission's July call for advice on a possible Delegated Act on fees. The information will also be used to develop proportionate requirements for entities within the scope of IM model authorization, especially for smaller entities (the so called "Phase 5" and "Phase 6" entities) as part of upcoming mandates under EMIR 3.

The deadline for responses to the survey is November 29. Closer to the EMIR 3 publication, the EBA will publish on its website operational clarifications aimed to ensure a smooth, convergent entry into force of EMIR 3 requirements in the EU.

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