top of page

Regulatory Alert: EMIR Data-Collection for Initial Margin Model Validation

  • Antonis Hadjicostas
  • 2 days ago
  • 2 min read
ree

On December 12, 2025, the Cyprus Securities and Exchange Commission (CySEC) published a Circular C740, addressing the upcoming regulatory requirements under the European Market Infrastructure Regulation (EMIR). This circular sets out precise data-collection expectations for regulated entities in Cyprus that are subject to EMIR’s initial margin model authorisation and validation procedures.


Background: EMIR and Initial Margin Models


Under Article 11(3) of EMIR (Regulation (EU) No 648/2012), firms that exchange initial margin and use internal margin models—such as the ISDA Standard Initial Margin Model (SIMM)—must seek prior authorisation from their competent authority before implementing or continuing to use such models. Moreover, validation of these models by the European Banking Authority (EBA) is required before they can be adopted across the EU.


What is Required


The core purpose of Circular C740 is to ensure that regulated entities report the necessary information to CySEC by 16 January 2026 to facilitate:


  • Identification of which entities need to apply for authorization and subsequent EBA validation.

  • Onboarding of these entities to the EBA’s ISDA SIMM Validation System (under development).


To this end, the circular instructs entities to send:


  1. The standard data set specified in the EBA’s opinion on initial margin model applications.

  2. A completed template (titled “EMIR IMM application for authorisation_LEI of Regulated Entity” and referenced as “EMIR IMM validation_LEI of Regulated Entity.xlsx”) — submitted to CySEC via email to emir@cysec.gov.cy.


This information will then be transmitted by CySEC to the EBA for validation purposes.


📌 Key Takeaways for Compliance Teams


For compliance officers in Cyprus-regulated entities (investment firms, UCITS, AIFs, non-financial counterparties), Circular C740 imposes urgent data submission requirements that must be prioritised to avoid regulatory gaps.


  1. Identify whether your entity exceeds EMIR initial margin thresholds.

  2. Prepare the required datasets and complete the CySEC/EBA templates.

  3. Submit all data to CySEC no later than 16 January 2026.

  4. Ensure readiness for the next phase: EBA validation of internal margin models.


Deadline


Regulated entities must submit their data to CySEC by 16 January 2026, creating an immediate compliance priority for affected firms.


Entities that fail to submit the required data will not be onboarded to the EBA validation system, effectively preventing them from applying for the EBA validation and thereby risking non-compliance with EMIR.

 
 

The material reflected in our website, including Blog material, is for informational purposes only and does not constitute legal advice, consulting, or any other professional advice. Please seek independent professional guidance for your specific needs.

​

All rights reserved. No part of this work may be reproduced, stored in a retrieval system of any nature, or transmitted, in any form or by any means including photocopying and recording, without the prior written permission of the ENAH Services Ltd. The reproduction or transmission of all or part of the work, whether by photocopying or storing in any medium by electronic means or otherwise without the written permission of the owner is strictly prohibited and the commission of any unauthorised act in relation to the work will result in civil and/or criminal actions. 

bottom of page