EACH Response: CPMI-IOSCO Margins & PQD implementation - June 2026 - EACH - European Association of CCP Clearing Houses

EACH supports global consistency in implementing margin transparency standards

EACH has responded to the CPMI-IOSCO consultation on updated guidance and public disclosures for implementing initial margin proposals. EACH welcomes the guidance as an appropriate global standard and highlights the importance of maintaining international consistency and avoiding regulatory gold-plating. We particularly emphasise:

The importance of the CPMI-IOSCO guidance as an appropriate global standard.
Consistent implementation across jurisdictions
The benefits of historical stress events over hypothetical scenarios in margin simulators.
That both CCPs and clearing members have a role to play in providing margin transparency.