On 17 December 2024, the European Banking Authority issued a no action letter stating that Member State competent authorities (NCAs) should not prioritise any supervisory or enforcement action in relation to the processing of applications for initial margin (IM) model authorisation received as a result of the entry into force of the European Market Infrastructure Regulation 3 (EMIR 3).

The no action letter describes a registration process for counterparties in scope of IM model authorisation, specifying in its annex the information that counterparties should include as part of any first application submitted to NCAs after the entry into force of EMIR 3, as well as for subsequent yearly updates to such application. However, per the no action letter NCAs should not prioritise the processing of such applications, until the draft regulatory technical standards on Initial Margin Model Validation and the guidelines on application and authorisation process mandated under EMIR 3 come into application, as those regulatory deliverables are expected to specify key requirements for the application and authorisation process, as well as for the assessment of model changes, which are missing at the moment.