Each September until 2022*, increasing numbers of entities will be required to meet initial margin regulations as the threshold level for compliance reduces. Preparation for meeting these requirements will take significant time, and will involve intensive work to ensure systems, processes and documentation are in place.
ISDA has published a fact sheet that sets out the steps firms should take when preparing to comply with regulatory initial margin requirements. These are not necessarily presented in chronological order – the precise order and timing will depend on a firm’s specific circumstances.
STEP 1: Identify in-scope entities early
STEP 2: Make early disclosures to counterparties
STEP 3: Exchange information on compliance
STEP 4: Identify special cases
STEP 5: Establish custodial relationships
STEP 6: Prepare for compliance
STEP 7: Negotiate/execute documentation
STEP 8: Finalize preparations
- Updated in August 2020 to account for new Basel Committee on Banking Supervision/IOSCO implementation schedule.
Click on the attached PDF to read the full list of steps.
Documents (1) for Getting Ready for Initial Margin: The Steps to Take
Latest
ISDA In Review – August 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in August 2026.
Remove Bureaucracy from Cross-margin Approvals
Cross-margining programs play a critical role in financial markets. By ensuring margin requirements more closely reflect the actual risk of a portfolio of products, they reduce liquidity strain and improve market efficiency, both of which will become even more important...
Joint Response on CCP Resolution
On September 7, ISDA and FIA responded to a Bank of England (BOE) discussion paper on central counterparty (CCP) resolution. The associations support greater clarity on valuation capabilities prior to a crisis scenario and the boundary between recovery and resolution,...
Expanding Legal Agreement Coverage in the CDM
This paper examines the recent extension of the Common Domain Model (CDM)1 to represent two of the most significant, and previously undeveloped, areas of its legal agreement model: umbrella agreements and contract amendments. Umbrella agreements are widely used to document...