Read the CySEC Circular C740
Memo #63-2025
CySEC Circular No: C740
Date: 18/12/2025
Subject: Data collection for onboarding of financial and non-financial counterparties subject to the obligation to apply for authorisation and validation for their initial margin models in accordance with Article 11(3) of Regulation (EU) No 648/2012 on OTC derivatives, central counterparties and trade repositories (‘EMIR’)
Purpose: To bring to the attention of the Regulated Entities that the EBA launched a formal data-collection exercise through competent authorities to identify all EU counterparties required to apply for validation of their ISDA SIMM.
In Summary:
CySEC has issued the Circular C740 on 12/12/2025 to inform the Cyprus Investment Firms, UCITS and where relevant, their Management Companies, the Alternative Investment Funds (AIFs) established or managed in Cyprus and where relevant, their Alternative Investment Fund Managers (AIFMs) and Non-Financial Counterparties, that on 07/11/2025, the European Banking Authority (EBA) launched a formal data-collection exercise through competent authorities to identify all EU counterparties required to apply for validation of their ISDA Standard Initial Margin Models (ISDA SIMM).
The Circular C740 refers to the relevant Regulatory framework, validation process and Reporting.
CySEC notes that all Regulated Entities captured under the requirements for authorisation/validation of their IM models, are asked to submit to CySEC, by 16/01/2026, the following information:
i) The data set out in the Annex to the EBA opinion on the application of EMIR with respect to initial margin models with subject “EMIR IMM application for authorisation_LEI of Regulated Entity”.
ii) The data set out in the template which can be found here with the file name “EMIR IMM validation_LEI of Regulated Entity.xlsx”. It is noted that the above file name must be repeated in the email subject line.
CySEC further notes that Regulated Entities are urged to take the necessary action in order to ensure compliance with their EMIR obligations at all times.
The EBA data-collection exercise can be found on the following link:
The Annex to the EBA opinion on the application of EMIR with respect to initial margin models can be found on the following link:
The template “EMIR IMM validation LEI of Regulated Entity.xlsx” can be found attached to the Circular C740.
Read the CySEC Circular C740
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