On 5 March 2025, the European Banking Authority (EBA) issued a Discussion Paper on fees to be paid by financial and non-financial counterparties requiring the validation of pro forma models under the European Market Infrastructure Regulation (EMIR).

The European Commission previously issued a request for technical advice on a possible delegated act on fees to be charged to financial and non-financial counterparties requiring the validation by EBA of pro forma models, with the request to submit such advice by Q2 2025.

The Discussion Paper outlines:

  • The EBA budgeting approach (section 4.2).
  • The main EBA costs incurred by the EBA for the performance of its new tasks resulting from its new role as central validator of pro-forma IM models (section 4.3).
  • The expected fees per counterparty including the calculation methods (section 4.4).
  • The modalities of payment (section 4.5).

Next steps

The consultation closes on 7 April 2025.