Key dates
- 2026-05-06
- CPMI-IOSCO published the consultation on updated CCP resilience guidance and PQD disclosures
- 2026-06-30 Deadline
- Deadline to submit consultation comments to the CPMI and IOSCO secretariats
Suggested considerations
- Compliance teams may wish to review the January 2025 BCBS-CPMI-IOSCO initial margin report to map likely changes to CCP resilience guidance and PQD disclosure expectations.
- CCPs may wish to assess whether their current margin simulation tools, responsiveness metrics, override governance, and public disclosures could support the kind of targeted enhancements described in the consultation.
- Clearing members and clients may wish to evaluate how more detailed CCP disclosures could affect margin forecasting, model validation, and due diligence workflows.
- Firms may wish to prepare consultation submissions by the 30 June 2026 deadline, particularly if they have views on feasibility, data granularity, disclosure lags, or governance implications.
- Compliance and legal teams may wish to monitor whether the final amendments create new reporting or disclosure obligations under the revised CCP guidance and PQD standards.
What changed
The consultation proposes targeted additions to the CPMI-IOSCO 2017 guidance on the resilience of central counterparties and to the 2015 PQD standards for CCPs. The stated purpose is to incorporate relevant elements of the January 2025 BCBS-CPMI-IOSCO final report on transparency and responsiveness of initial margin in centrally cleared markets.
The areas specifically addressed are simulation tools, the measurement of initial margin responsiveness, margin model governance frameworks, the use of margin model overrides, and CCP public disclosures.
Compliance impact
The publication is a consultation, so the immediate legal severity is moderate rather than binding, but it signals concrete supervisory direction on CCP margin transparency and governance. If adopted, the amendments could increase disclosure granularity and scrutiny of margin-model responsiveness, simulation tools, and override controls for CCPs and their clearing relationships.