EMIR Initial Margin Reporting – What the New IM Model Authorisation Regime Means for Your Firm
Last updated: March 2026 If your firm uses ISDA SIMM to calculate initial margin on non-centrally cleared OTC derivatives, you have operated for years without needing formal supervisory approval for that model. That changes under EMIR 3. For the first time, every counterparty using an IM model must obtain prior authorisation from its competent authority….