CPMI-IOSCO Initial Margin Guidance: Simulators, Overrides, New PQDs

On 6 May 2026 the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) opened a consultation that would rewrite parts of two documents every central counterparty already works to: the 2017 CCP resilience guidance and the 2015 public quantitative disclosure standards. The CPMI-IOSCO initial margin package folds six of the eight in-scope proposals from the January 2025 report on the transparency and responsiveness of initial margin into the resilience guidance, and the other two into the disclosure standards. Comments were due by 30 June 2026, so the window is now closed. As of 30 August 2026, no final report has been published and CPMI-IOSCO has not announced a publication date.

The stakes sit with two audiences at once. Under the May 2026 draft resilience guidance, CCPs should consider making margin simulation tools available to all clearing members and, where feasible, their clients; the draft also expands model and override disclosures. Separately, the proposed PQD amendments add disclosures that CCPs publish on their websites rather than file with a regulator. Clearing members and their clients are intended beneficiaries: the policy work is designed to help participants understand potential future margin requirements and improve liquidity preparedness during market stress. The committees characterise each addition as clarifying acceptable ways of observing the Principles for Financial Market Infrastructures (PFMI), giving substance to existing standards rather than introducing fresh obligations layered on top of them.

Related reading: ESMA 6th CCP Stress Test: What Clearing Members Should Expect

The consultation calendar at a glance

This consultation amends guidance and disclosure standards rather than introducing a remittance regime, so there is no filing date to key on. The two documents being amended have histories stretching back a decade: the public quantitative disclosure standards were first published in February 2015 and the CCP resilience guidance in July 2017. The policy foundation for this package was set in January 2025, when BCBS-CPMI-IOSCO published the final report Transparency and responsiveness of initial margin in centrally cleared markets, which set out ten final policy proposals; the May 2026 CPMI-IOSCO consultation addresses proposals 1 to 8. The consultation itself opened on 6 May 2026, with responses due to the CPMI Secretariat (cpmi@bis.org) and the IOSCO Secretariat (margin@iosco.org) by 30 June 2026; that window is now closed. The one forward-looking date the calendar does not yet carry is the publication of the final report, which CPMI-IOSCO has not announced. Once published, the committees would encourage CCPs to implement the disclosure changes within 12 months. Until then, any implementation work is against text that is still in tracked changes.

What the CPMI-IOSCO initial margin consultation changes

The consultative documents present the amendments as tracked changes to existing text, framing each addition as clarifying how CCPs observe the existing PFMI standards rather than creating obligations beyond them. The guidance identifies acceptable ways of observing the principles without prescribing the only way. That modality applies to the resilience-guidance amendments, while the PQD amendments separately add new public-disclosure content, including proposed item 6.9 on margin responsiveness.

The practical reach is still real. The resilience guidance itself notes that a CCP may need to change its rules, procedures, governance arrangements and risk-management framework for its practices to be consistent with the guidance. If finalised, the amendments would make the guidance more granular on how CCPs can demonstrate observance of the PFMI; the consultation does not itself determine what any particular authority will require in its supervisory assessment. For firms that run the central clearing pipeline day to day, our EMIR reporting guide covers how the EU applies its own binding CCP framework under EMIR alongside the international PFMI-based standards; the CPMI-IOSCO guidance is not itself directly binding EU legislation.

Eight proposals in, two out

The January 2025 report contained ten policy proposals. This consultation only touches the eight that fall to CPMI and IOSCO. Proposals 1 to 4 and 7 to 8 go into the CCP resilience guidance through targeted additions to the introduction (paragraph 1.1.7) and to sections 2.2.7, 2.2.14, 2.2.22, 2.2.23 and 5.2.42, complemented by a new annex. Proposals 5 and 6 go into the public quantitative disclosures, amending the introduction, section 6, the explanatory notes and Annex 1.

The two proposals left out matter as much as the eight in. Proposals 9 and 10 address clearing-member transparency: how a clearing member explains its margin to clients, and how it reports to the CCP. Both proposals sit outside the scope of these amendments; the direct addressee of every in-scope change is the CCP, with the clearing member appearing as the party that receives simulators, disclosures and override explanations. The client-facing obligations sit in the proposals the committees have not yet moved into a standard.

Margin simulators and model disclosures

The first block of proposals addresses what a clearing member can see before a stress event, covering the visibility available in advance rather than the analysis done during or after one. The May 2026 draft guidance says CCPs should consider making margin simulation tools available to all clearing members and, where feasible, their clients, including prospective clearing members and clients, where necessary, this access may be paired with an appropriate non-disclosure agreement. Proposal 2 sets the minimum functionality: the tool should calculate margin for a number of the CCP’s stress-test scenarios, including key historical stress events, for both current and hypothetical portfolios, and it should reflect the CCP’s main add-on charges on top of baseline or core initial margin.

The trap here is a simulator that only prices core margin for today’s market. The report is explicit that some existing tools cover core initial margin for current conditions alone, without add-ons and without stressed or hypothetical scenarios. The January 2025 report says that forward-looking simulator functionality and inclusion of add-ons could help participants understand potential total liquidity demands and how a model may respond across market scenarios. If your desk relies on a CCP simulator that stops at core margin, that is the gap the proposal is written to close.

Proposals 3 and 4 move from the tool to the model behind it. Proposal 3 would have CCPs give members, and where feasible clients, enough qualitative information to understand the model in use, for example SPAN or a value-at-risk approach, and the calibration of the parameters that drive the size and speed of margin changes: lookback period, liquidation horizon, confidence interval and the method-specific parameters, plus the logic and thresholds behind add-ons. Proposal 4 would have CCPs publicly disclose and describe the anti-procyclicality tools in the model and, at a high level, the components that affect how responsive the model is. For teams that build initial margin numbers into their own returns, our note on EMIR initial margin reporting shows where those figures already surface in the EU regime.

New public quantitative disclosures

Proposals 5 and 6 amend the public quantitative disclosure standards rather than a regulatory filing template. The public quantitative disclosures use a common publication format, with update frequencies specified item by item in the matrix; the margin items amended or added by this consultation are quarterly. Proposal 5 would add, wherever the data are available, a split between core initial margin and margin add-ons for total initial margin required (disclosure item 6.1), the results of initial margin backtesting for the most relevant contracts per clearing service (item 6.5), and a split by clearing service and currency of the average and maximum total variation margin paid to the CCP by participants (items 6.6 and 6.7). All of it sits in Part 6 of the disclosures, the margin section.

Proposal 6 adds something genuinely new: a standardised measure of margin responsiveness. The May 2026 proposed PQD text would require CCPs to calculate and disclose item 6.9 for the most relevant products per clearing service. The January 2025 policy proposal also called for computed daily time series to be made available to regulators on request, but that authority-facing requirement is not reproduced in the May 2026 proposed PQD text. The January 2025 policy report expected a minimum of five to 20 relevant products. The May 2026 proposed PQD text uses a proportionality standard instead: the number disclosed should be commensurate with the CCP’s size and scope, and the CCP should explain its choice of relevant products. Where an underlying price or value is not publicly available, the proposed Annex 1 requires publication of that price or value at the relevant dates. The measure is defined in the report’s analytical annex over two observation periods, so a CCP cannot invent its own denominator; the value of a responsiveness figure is that it means the same thing across CCPs, which is what makes the disclosures comparable in the first place.

The January 2025 Proposal 5 introduced the additional breakdowns ‘wherever available’, but the May 2026 proposed PQD text places the new product-level content directly into item 6.5 and states that, at a minimum, CCPs are expected to disclose specified backtesting information. The general PQD introduction allows a CCP to explain data that are genuinely not relevant or, more rarely, unavailable; it does not state that existing absence of product-level backtesting removes the proposed item 6.5 expectation.

Overrides and the responsiveness framework

The last block, proposals 7 and 8, is where governance meets disclosure. The May 2026 draft guidance says each CCP should define an internal analytical and governance framework for assessing responsiveness within the broader context of margin coverage and cost, and should seek market-participant input, for example through the risk committee, when designing or materially changing that framework. The January 2025 policy proposal also referred to communicating the framework and parameter choices to relevant authorities, but that wording is not reproduced in the May 2026 draft annex. The report is clear that responsiveness cannot be judged in isolation: a full assessment balances coverage, average cost and a measure of responsiveness over the same lookback period. The January 2025 report says it would be reductive to assess model performance on responsiveness alone and instead describes a holistic assessment across margin coverage, average cost and responsiveness.

Proposal 8 addresses model overrides: discretionary and temporary deviations from standard model-driven margin estimates introduced through expert judgement, governance intervention, exception handling or other rationale. Authorities saw a run of these during the March 2020 dash for cash and the 2022 commodities volatility, with CCPs adjusting parameters such as the scan range, volatility floor, margin period of risk and confidence interval. In some cases members received no prior warning and minimal explanation afterwards. The May 2026 draft guidance says a CCP should maintain clear governance procedures and ex-post reviews of overrides, publicly disclose the circumstances in which discretion may be applied and the governance procedures used, and give any clearing member subject to an override a qualitative explanation of the reasons. The January 2025 policy proposal also called for full governance procedures and aggregate override size and duration to be shared with authorities, but those authority-facing elements are not reproduced in the May 2026 draft annex. The ESMA CCP default-simulation exercise tests the default-management side of the same resilience question; overrides are the margining side of it.

Why the scope excludes uncleared markets

The May 2026 consultation is limited to CCP-related amendments implementing proposals 1 to 8 for centrally cleared markets. The January 2025 final policy report separately stated, in footnote 55 to Proposal 9, that where a clearing member’s client-margin decisions draw on both cleared and uncleared activity, documentation should note the interaction without detailing the uncleared specifics. Proposal 9 is outside the May 2026 consultation. The margin transparency work that touches bilateral portfolios runs on a separate track, and the exchange-of-margin mechanics there are a different regime entirely, as our note on the EMIR bilateral margin RTS amendments sets out. Treating a CCP disclosure standard and an uncleared margin rule as one project is a common way to widen scope past what the text supports.

How this reaches a CCP in your jurisdiction

The PFMI are international standards that take effect through each jurisdiction’s regulatory framework. CPMI-IOSCO guidance reaches a CCP through the authorities responsible for its regulation, supervision and oversight, each of which applies the principles through its own regime. In the European Union that is EMIR and the supervision run by national authorities alongside ESMA; in other jurisdictions it is the local CCP framework. The consultation says each CCP, together with its authorities, should take the guidance into account when developing its approach to observing the PFMI, and that authorities perform their own assessments of observance.

The May 2026 consultation leaves the resilience-guidance amendments without a new implementation date. Each CCP, together with the authorities responsible for its regulation, supervision and oversight, should take the guidance into account, while the cover note separately says CPMI-IOSCO would encourage implementation of the PQD changes within 12 months of publication of the final report.

What CCPs and clearing members can do before the final report

The text is not final, so the work now is preparation rather than implementation. For a CCP, the concrete steps are to read the tracked changes against the current resilience guidance and disclosure standards, identify where existing simulators fall short of the proposal 2 minimum, and check whether the model documentation shared with members already covers the parameters named in proposal 3. For a clearing member, the useful move is to inventory what each CCP already provides against the eight proposals, so the gap analysis is ready when the final report lands.

One point is worth clarifying for reporting teams specifically: the new public quantitative disclosure items are public disclosures that a CCP posts in a common format for participants and the market to compare across venues. The PQDs are public disclosures for stakeholders including authorities, participants and the public, and the May 2026 draft requires publication through the CCP’s website. The January 2025 policy proposal contemplated a more granular daily responsiveness time series for regulators on request, but that authority-facing requirement is not reproduced in the May 2026 proposed PQD text. Getting that distinction right decides which team owns the build.

Frequently Asked Questions

Is the CPMI-IOSCO initial margin consultation still open for comment?

No. The comment period closed on 30 June 2026. Responses will be published on the BIS and IOSCO websites unless a respondent requested otherwise. As of 30 August 2026, no final report has been published and CPMI-IOSCO has not announced a publication date.

Does this create a new reporting obligation for clearing members?

The eight in-scope proposals (1 to 8) address CCPs. Proposals 9 and 10 cover clearing-member transparency duties, including how a member explains margin to clients and reports to the CCP; those proposals fall outside this consultation. A clearing member’s role here is as the recipient of simulators, model disclosures and override explanations, with no filing duty of its own.

Are the public quantitative disclosures a template we send to a regulator?

The public quantitative disclosures are published by the CCP in a common format, with the completed matrix provided on the CCP’s website. Proposed item 6.9 is a quarterly public disclosure. The January 2025 policy proposal also contemplated a computed daily responsiveness time series for regulators on request, but that authority-facing requirement is not reproduced in the May 2026 proposed PQD text.

What is the standardised measure of margin responsiveness?

It is a new disclosure item, defined in the analytical annex of the January 2025 report, that captures how much initial margin moves over defined observation periods for the most relevant contracts in a clearing service. Its purpose is comparability: a common definition lets a member read one CCP’s responsiveness against another’s instead of a bespoke metric per venue.

How do margin model overrides fit in if they are meant to be rare?

Overrides are the manual adjustments a CCP makes when it judges the model output wrong for current conditions, seen in clusters during March 2020 and the 2022 commodities stress. The May 2026 draft guidance keeps that discretion within a governance and disclosure framework: a CCP should maintain governance procedures and ex-post reviews, publicly disclose the circumstances in which discretion may be applied and the governance procedures used, and give a qualitative explanation to any clearing member subject to an override. The January 2025 policy proposal also included authority-facing reporting of aggregate override size and duration, but that element is not reproduced in the May 2026 draft annex.

Do the changes apply to our bilateral, uncleared margin as well?

The May 2026 consultation is limited to CCP-related amendments for centrally cleared markets. The separate January 2025 Proposal 9, which is outside this consultation, says that where a clearing member’s client-margin decisions draw on both cleared and uncleared activity, documentation should note the interaction without detailing the uncleared specifics.

When would a CCP have to make the disclosure changes?

CPMI-IOSCO would encourage CCPs to implement the disclosure changes within 12 months of the final report’s publication. Because the final report is not out, no 12-month period is running yet. The resilience-guidance changes reach a CCP through its own authorities’ assessment of PFMI observance rather than on a fixed date.

Related Articles

• ESMA 6th CCP Stress Test: What Clearing Members Should Expect: how ESMA tests EU CCP resilience and what clearing members feed into it.
• EMIR Initial Margin Reporting: where initial margin figures surface in the EU derivatives reporting regime.
• EMIR Reporting Explained: how the EU turns central-clearing principles into binding reporting obligations.
• ESMA CCP Default Simulation: the default-management fire drill that sits alongside the margining questions here.
• EMIR Bilateral Margin RTS Amendments: the separate, uncleared-margin regime this consultation deliberately excludes.
• EMIR 3 CCP Admission Criteria RTS: the EU rules governing which CCPs clearing members can use.

Key Takeaways

The comment window closed on 30 June 2026 and the final report is pending with no published date, so any implementation work before that report lands is against text still in tracked changes. The package amends two existing documents, the 2017 CCP resilience guidance and the 2015 public quantitative disclosures, framing every addition as clarifying how CCPs observe the PFMI rather than introducing new standards. Eight of the ten January 2025 proposals are in scope; proposals 9 and 10, the clearing-member transparency duties, remain outside these amendments.

Operationally, the May 2026 draft guidance says CCPs should consider making margin simulators available to all clearing members, with minimum functionality covering specified stress scenarios and main add-ons beyond core margin. The proposed PQD amendments add the core-margin/add-on split to item 6.1, product-level backtesting detail to item 6.5, clearing-service and currency splits to items 6.6 and 6.7, and a new quarterly item 6.9 on margin responsiveness for the most relevant products; the draft does not specify a five-to-20-product minimum. For model overrides, the draft annex calls for governance and ex-post review, public disclosure of the circumstances and governance procedures, and a qualitative explanation to affected clearing members. The consultation concerns centrally cleared markets.

Sources and References

• CPMI-IOSCO, Consultation on updated guidance and public disclosures to implement initial margin proposals, 6 May 2026 (cover note, resilience guidance and public quantitative disclosures with proposed amendments).
• BIS media release, CPMI-IOSCO publishes for consultation updated guidance and public disclosures to support the implementation of initial margin proposals, 6 May 2026.
• BCBS-CPMI-IOSCO, Transparency and responsiveness of initial margin in centrally cleared markets: review and policy proposals (final report), January 2025.
• CPMI-IOSCO, Resilience of central counterparties (CCPs): further guidance on the PFMI, July 2017.
• CPMI-IOSCO, Public quantitative disclosure standards for central counterparties, February 2015.
• BCBS-CPMI-IOSCO, Review of margining practices, September 2022.
• CPSS-IOSCO, Principles for financial market infrastructures, April 2012.

Reading the tracked changes before the final report

The useful output of this consultation for a CCP or a clearing member is a gap list. The tracked changes in the two consultative documents show the amendments in paragraph 1.1.7 and sections 2.2.7, 2.2.14, 2.2.22, 2.2.23 and 5.2.42 of the resilience guidance, together with the introduction, Part 6, explanatory notes and Annex 1 of the public quantitative disclosures. Map your current simulators, model documentation, override governance and disclosure items against those, and the day the final report lands you already know what has to change and who owns it.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.