Uncleared Margin Requirements: What the 2025 BCBS-IOSCO Review Found

On 12 December 2025 the Basel Committee on Banking Supervision and the International Organization of Securities Commissions published a joint review of how the uncleared margin requirements framework has been implemented, and the headline for reporting and collateral teams is that nothing in the rulebook moves. The review found no material issues with the framework for margin on non-centrally cleared derivatives, and the two standard-setters propose no changes to it. For buy-side firms that crossed into initial margin scope in the final phase, and for the dealers who have posted collateral since the first phase in 2016, the standard they built to still stands.

That is the useful signal, and it is worth reading precisely. The December 2025 document creates no new return, no new template, and no new threshold. It commits the BCBS and IOSCO to keep watching, through supervisory information exchange and the sharing of experiences among members, so that evolving market practice stays inside the framework as it develops. The operational work for buy-side and sell-side teams therefore sits elsewhere: in the local implementations that keep moving, particularly the EU refinements to bilateral margin under EMIR.

Related reading: EMIR bilateral margin RTS amendments

What the December 2025 review actually concluded

The document is short, at 24 pages, and its conclusion is narrow. The BCBS and IOSCO assessed the framework, published in response to the 2011 G20 call to make derivatives markets more resilient, and reported that it has been effectively applied. Their central finding is that the amount of margin exchanged for non-centrally cleared derivatives has increased materially since 2012, which is the resilience the G20 asked for. The framework reached what the standard-setters describe as a steady state once the final implementation phase took effect in 2022, and it held up through recent episodes of market stress.

The review drew on three inputs: a 2024 quantitative impact study, surveys of the members of the BCBS-IOSCO Working Group on Margining Requirements, and recent international work on margin. From those inputs the Working Group recommends continued monitoring rather than reform. The wording matters for anyone scoping a compliance change: the standard-setters explicitly do not propose amendments, and the monitoring recommendation is framed as supervisory information exchange and the sharing of experiences among WGMR members; the December 2025 report does not create a new reporting obligation for firms.

The review reads as a clean bill of health with a supervisory footnote. The footnote is that market practice keeps evolving, and the authorities want the option to coordinate if it evolves in a way the framework did not anticipate. That is a governance posture with no filing consequence for firms.

The dates that anchor the framework

Because the review confirms the framework instead of changing it, the operative calendar is the one already in force. The BCBS-IOSCO framework was first published in 2013, revised in 2015 and 2019, and revised again in April 2020; the current BCBS text is consolidated in the Basel Framework margin standard (MGN). Phase-in of variation margin for the largest covered entities began on 1 September 2016. From 1 March 2017, the BCBS-IOSCO variation-margin requirement applied to new contracts between covered entities; exchange of variation margin on older contracts remained subject to bilateral agreement, and instrument-specific and local-regime rules still had to be applied.

Initial margin was slower to reach its full scope. Phase five, capturing groups with an average aggregate notional amount above EUR 50 billion, took effect on 1 September 2021. The final phase, at an average aggregate notional amount above EUR 8 billion, followed on 1 September 2022. Both dates are each a year later than first planned: the BCBS and IOSCO deferred the final two phases by twelve months in April 2020, giving firms operational room during the pandemic. The December 2025 review assesses implementation now that the final phase has been in place since 2022 and the framework has generally reached a steady state.

The consolidation into the Basel Framework is worth noting for anyone navigating older guidance. The phase-in language now lives in the margin standard under the consolidated Basel Framework and no longer in a standalone document, so vendor material that cites the original standalone framework may point to superseded text.

Why no change to the uncleared margin requirements framework still matters

A confirmation is only useful if you know what it confirms, and the framework rests on two very different margin obligations that teams still conflate. Variation margin covers current exposure and, under the BCBS-IOSCO baseline, the full amount is exchanged on a regular basis, for example daily; the governing local regime determines the exact calculation and collection timing. Initial margin covers the potential future exposure that could build up between the last exchange of variation margin before a counterparty defaults and the point at which the trade is replaced or hedged. The EUR 8 billion AANA test governs initial-margin scope only. Variation-margin scope is determined separately under the applicable instrument, counterparty and local-regime rules.

Three numbers do the work, and they measure three different things. AANA is an initial-margin scope test. Under the BCBS-IOSCO framework, from 1 September 2022 a covered entity whose group AANA for March, April and May exceeds EUR 8 billion is subject to initial-margin requirements when transacting with another covered entity that also meets that condition; the binding scope is determined by the applicable local regime. Once the relevant groups are in scope, the BCBS-IOSCO initial-margin threshold may be set no higher than EUR 50 million. The threshold is applied at consolidated-group level across all non-centrally cleared derivatives between the two consolidated groups taken together. Under Article 25 of Regulation (EU) 2016/2251, counterparties may agree a minimum transfer amount, but it must not exceed EUR 500,000 or the equivalent in another currency. Separate minimum transfer amounts may be agreed for initial and variation margin provided that their sum does not exceed EUR 500,000. Read those three as scope, buffer, and plumbing, and the framework stops looking like a single wall of collateral.

This is where the mislabelling bites. The EUR 8 billion AANA test is specific to initial-margin scope. Variation-margin scope must be determined under the applicable rules for the counterparties and transactions concerned, regardless of whether the group clears the AANA threshold. Confusing the AANA scope test with the EUR 50 million exchange threshold produces either over-collateralisation or a control gap, and a review that leaves both numbers untouched is a reminder to check that your documentation still describes them correctly. For teams that report initial margin figures onward, our note on EMIR initial margin reporting covers how those amounts surface in supervisory data.

What the review did not do

The most common way to misread a document like this is to treat a review as a reform. The BCBS-IOSCO review is an assessment of implementation, and it carries no legislative force in any jurisdiction. It does not change EMIR, it does not change the EU bilateral margin RTS, and it does not change the equivalent rules in the United Kingdom, Switzerland, the United States, or the Asia-Pacific regimes. A global stocktake sits above the national instruments that actually bind counterparties, and reading it as a rule change is the error to guard against.

It also does not touch model approval. Firms that calculate initial margin with a model, such as the ISDA Standard Initial Margin Model, still run that model under their local rules, and the December 2025 review neither endorses nor amends any particular methodology. The standardised initial margin schedule remains the alternative to a model, exactly as before. Nothing in the review requires a firm to recalibrate, revalidate, or re-document its initial margin calculation.

The review does have something to say about the future, and it is narrower than firms tend to expect. The standard-setters flag continued monitoring precisely because market practice evolves, so the honest reading is that the framework is stable now and the authorities have reserved the right to revisit it through coordination instead of a fixed workplan.

Where the real action is: EU refinements to bilateral margin

The evolving market practice the review gestures at is visible in the EU, where the bilateral margin regime under Article 11 of EMIR and Commission Delegated Regulation (EU) 2016/2251 has kept moving even as the global standard held still. Two developments matter for firms with EU-facing books.

The first is already law. Regulation (EU) 2024/2987, the EMIR 3.0 package, inserted a new Article 11(3a) into EMIR under which single stock options and equity index options that are not cleared by a central counterparty are not subject to the risk-management procedures requiring the exchange of collateral. That converts a long-running temporary exemption for equity options into a settled carve-out, and the ESAs’ August 2026 draft RTS propose to amend the EU bilateral margin RTS to remove the outdated transitional arrangements for those equity options. For a desk trading uncleared equity options, that is a genuine EU scope change arising from directly applicable EU law, distinct from any BCBS-IOSCO recommendation.

The second is in progress. On 3 August 2026, the European Supervisory Authorities published Final Report ESA 2026 07 containing draft regulatory technical standards amending Regulation (EU) 2016/2251. Under current Article 28(1), where one counterparty’s AANA for March, April and May of the preceding year is below EUR 8 billion, counterparties may refrain from collecting initial margin on new OTC derivative contracts entered into during the relevant calendar year, while existing contracts remain subject to the existing initial-margin requirements. The draft RTS would extend the derogation to existing contracts and would also change the timing mechanics: where the March-to-May AANA for year X is below EUR 8 billion, the proposed exemption could be applied as early as 1 June of year X; where both counterparties are above EUR 8 billion, initial-margin requirements for new contracts would apply no later than 1 January of year X+1. The Final Report has been submitted to the European Commission for endorsement; following the Commission process, the RTS would be subject to scrutiny by the European Parliament and the Council before Official Journal publication. The draft is not yet in force.

Put together, the two EU items are the concrete version of the review’s abstract point. The global framework is stable, and the refinement is happening in the local instrument. Anyone tracking the EU line should follow it through our coverage of the EMIR 3 clearing thresholds and uncleared aggregate RTS, which sits alongside the margin RTS in the same reform cycle.

What buy-side and sell-side teams should check now

The value of a no-change review is that it frees teams to fix documentation instead of chasing a deadline. For sell-side dealers, who have exchanged margin since the earliest phases, the review does not itself require changes to existing credit support annexes, custodial arrangements or threshold monitoring. Teams should nevertheless check that their documentation describes the AANA scope test, the EUR 50 million exchange threshold and the minimum transfer amount correctly, and, for EU books, reflects the EMIR 3.0 equity-option carve-out.

For buy-side firms, particularly those that crossed the EUR 8 billion AANA line in the final phase, the live question is the below-threshold path. A buy-side counterparty whose applicable AANA falls below EUR 8 billion needs to determine, under its governing regime and the applicable counterparty- or group-level calculation rules, whether existing initial-margin arrangements must be maintained on legacy trades. In the EU that answer is the one the draft RTS would change, so it is worth watching before assuming. Cross-border books add a wrinkle the review does not resolve: a European counterparty facing a firm in a jurisdiction that already exempts legacy trades is managing two different answers to the same question, which is exactly the divergence the ESAs want to close. Transparency on initial margin numbers is a related thread, and our summary of the CPMI-IOSCO initial margin disclosure guidance covers how those figures are expected to be published.

For both sides, the framing to hold onto is that the review changes the supervisory conversation, not the counterparty one. If you want the wider EMIR context that surrounds the margin rules, our EMIR reporting guide sets out how the risk-mitigation obligations sit next to the transaction-reporting ones.

Frequently Asked Questions

Does the BCBS-IOSCO review create any new reporting obligation for firms?

No. The review is an assessment of implementation and proposes no changes to the framework. The continued monitoring it recommends is supervisory information exchange between BCBS and IOSCO members; it is not a new data submission from counterparties. Any reporting obligations a firm has continue to come from its national or regional rules, such as EMIR in the EU. This document does not create them.

If our group’s notional book falls below EUR 8 billion, can we stop exchanging initial margin entirely?

Not entirely, and the answer depends on your regime. In the EU, the Article 28(1) derogation in Regulation (EU) 2016/2251 currently lets counterparties stop collecting initial margin on new trades for a year when the AANA for March, April and May of the preceding year is below EUR 8 billion, but existing trades must still be margined. The ESAs have proposed draft RTS to extend that relief to existing contracts, though it is not yet in force. Variation margin continues regardless of the AANA level.

Does the review change how we run our initial margin model, such as ISDA SIMM?

No. The review does not endorse or amend any particular initial margin methodology. Firms continue to use an initial-margin model or the standardised schedule in accordance with the requirements of their applicable local regime, and the December 2025 review itself does not impose a new recalibration or revalidation requirement.

How are physically settled FX forwards and swaps treated?

The framework and its national implementations distinguish these instruments, which is a scope point the review did not alter. A firm should confirm the treatment in its governing instrument, because the physically settled FX carve-outs differ across regimes and this review did not change any of them.

Are uncleared equity options still in scope for margin in the EU?

EMIR 3.0, Regulation (EU) 2024/2987, inserted Article 11(3a) so that single stock options and equity index options not cleared by a central counterparty become exempt from the collateral-exchange requirements under that provision, a legislative position specific to EU-facing books, separate from the BCBS-IOSCO review, with no effect on the global standard.

Does a global review override the UK or Swiss margin rules?

No. The BCBS-IOSCO framework is a minimum standard that each jurisdiction implements through its own instrument, and after Brexit the UK regime is a separate onshored version. A firm follows the local rule that binds its counterparty relationship, and a global stocktake does not change that local text.

Why did the final implementation phase land in September 2022?

The BCBS and IOSCO deferred the final two phases by one year in April 2020 to give firms operational room during the pandemic. That moved phase five to September 2021 and the final phase, at the EUR 8 billion AANA threshold, to September 2022.

Related Articles

• EMIR Bilateral Margin RTS Amendments: how the EU is amending Regulation (EU) 2016/2251 for uncleared OTC derivatives.
• EMIR Initial Margin Reporting: how initial margin figures are calculated and surfaced in EU supervisory data.
• CPMI-IOSCO Initial Margin Disclosure Guidance: what the disclosure guidance expects on initial margin transparency.
• EMIR 3 Clearing Thresholds and Uncleared Aggregate RTS: the reform cycle that sits alongside the bilateral margin changes.
• EMIR Reporting Explained: the wider EMIR framework, from risk mitigation to trade reporting.
• ESMA Transaction Reporting Simplification: EMIR, MiFIR, SFTR: the parallel push to streamline EU derivatives and securities reporting.

Key Takeaways

The December 2025 BCBS-IOSCO assessment found no material issues and proposes no changes to the uncleared margin framework, so the continued monitoring it recommends runs between supervisory authorities and creates no new obligation, return, or threshold for firms. The framework is fully phased in: from 1 March 2017 the BCBS-IOSCO variation-margin requirement applied to new contracts between covered entities, subject to the framework’s instrument and local-implementation rules, and the permanent initial-margin phase at an AANA above EUR 8 billion began on 1 September 2022. Keep three numbers distinct in your documentation. EUR 8 billion is the principal BCBS-IOSCO AANA scope level for initial margin, the BCBS-IOSCO initial-margin exchange threshold may be set at up to EUR 50 million and is applied at consolidated-group level across all non-centrally cleared derivatives between the two groups, and the EU minimum transfer amount may be agreed at up to EUR 500,000; the applicable local rules and counterparty circumstances must be checked. Then confirm two EU-specific live items: EMIR 3.0’s Article 11(3a) exemption for uncleared equity options (already law), and the ESAs’ draft RTS extending the below-threshold derogation to existing contracts (not yet in force). A global review does not override local rules; the UK, Swiss, US, and EU regimes each bind through their own instrument, and that is where the work stays.

Sources and References

• BCBS-IOSCO, Review of the implementation of margin requirements for non-centrally cleared derivatives, 12 December 2025: bis.org publication page and BCBS d606.
• BIS press release, Global standard-setting bodies publish assessment of margin requirements for non-centrally cleared derivatives, 12 December 2025: bis.org/press/p251212.
• IOSCO copy of the December 2025 report (IOSCOPD812): iosco.org.
• BCBS-IOSCO, Margin requirements for non-centrally cleared derivatives (2013, revised March 2015): BCBS d317 (status: superseded).
• BCBS-IOSCO deferral of the final two implementation phases, April 2020: bis.org/press/p200403 and accompanying statement.
• Basel Framework, margin requirements standard (MGN): bis.org/basel_framework.
• Regulation (EU) No 648/2012 (EMIR): eur-lex.europa.eu.
• Commission Delegated Regulation (EU) 2016/2251 (bilateral margin RTS): eur-lex.europa.eu.
• Regulation (EU) 2024/2987 (EMIR 3.0), introducing Article 11(3a): eur-lex.europa.eu.
• ESAs Final Report ESA 2026 07, draft RTS amending Regulation (EU) 2016/2251 on initial margin for counterparties below the threshold, 3 August 2026: esma.europa.eu.

Reading a confirmation without over-reading it

The discipline this review asks for is restraint. A framework that the BCBS and IOSCO have declared sound is not a project, and the temptation to manufacture a workstream out of a clean assessment is the trap. The concrete next step for a buy-side or sell-side team is narrow: reconcile your documentation to the three thresholds, confirm your EU equity-option books reflect Article 11(3a), and put the ESAs’ draft RTS on the below-threshold derogation on the watch list against its Official Journal publication. Those three documentation steps close the December 2025 review for a buy-side or sell-side team.

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.