On 31 January 2025, the European Central Bank (ECB) issued FAQs on Initial Margin (IM) model approvals under the European Markets Infrastructure Regulation 3 (EMIR 3).

Among other things the FAQs deal with the following questions:

  • In light of the European Banking Authority (EBA) opinion on the application of EMIR 3 with respect to IM models, what will the ECB’s interim approach be, until the EBA regulatory technical standards/guidelines become applicable?
  • What if a significant institution is already using an IM model before the entry into force of EMIR 3?
  • When should a significant institution apply if it intends to use an IM model for the first time after the entry into force of EMIR 3?
  • What if multiple entities in the group are using or plan to use an IM model?
  • What happens when the EBA establishes its central validation function?