FAQ

ECC is adopting a next-generation margin model to reinforce its position as a sophisticated and resilient clearing house. This investment strengthens the entire market ecosystem by providing a platform for a more flexible model which will help to build and launch new products, clear new asset classes and, thus, enables future growth for the entire market.

The official announcement was published as a Circular. The upcoming R7 Release 4.0. will introduce a suite of TE Files and reports derived from simulation data. This release aims to support Independent Software Vendors and our members with their own risk applications, enabling them to advance their development efforts seamlessly. 

Additionally, with the R7 Release 4.1, production data will become available in the TE Files, reports, and the Cloud Prisma Margin Estimator. This will empower clearing members to understand, replicate, and predict margin calculations under the new ECC Prisma for Commodities model.

With R7 Release 4.0 scheduled for May 2026, ECC will start providing so-called "Transparency Enabler (TE) files. While the structure will be fixed and delivery channels can be tested, the content of the files needed to replicate margin figures produced by the new methodology will be provided with R7 release 4.1 scheduled for August 2026. Parallel run with operational figures from the new system will be available with release 5.0 from November 2026. Initial Margin according to the new model will only be called after the go live, currently planned for Q1 2027.

For further information please visit ECC Prisma for Commodities.

For further information please visit Prisma Migration.

ECC will use the same technical interfaces currently utilized by Eurex Clearing AG. This includes the Transparency Enabler Files (TE files) as well as member reports relevant to ECC’s product suite which allow for the replication of margin requirements. Additionally, an extra TE file (WGFCT) containing the weighting factor will be provided. A new member report (CP043) will also be introduced, with further details to be published in the Report Reference Manual in due course.

ECC is planning for a migration of all derivative products to the new initial margin methodology and system at the same time. The migration of all clearing members is planned for early 2027. The exact transition steps and dates will be consulted with clearing members and communicated accordingly. For further information please visit ECC Prisma Migration.

Recent years have provided a series of harsh, real-world stress tests that have clearly demonstrated the limitations of the static SPAN model. The extreme price swings and volatility in the commodities markets in 2022, sparked by the war in Ukraine, were a significant catalyst. These events created market conditions that were more extreme than the limited, predefined scenarios used by SPAN. VaR models can simulate a larger variety of potential scenarios, providing a more comprehensive and statistically robust measure of potential losses while inherently capturing correlations and offering a more precise and capital-efficient margining process.

The impact on initial margins depends on the portfolio composition and market conditions. ECC Prisma for commodities will generally allow for a much more adequate consideration of portfolio effects and thus more risk adequate estimation of margin requirements. While the pure market risk component of the model better reflects the core (market) risk of the portfolio, additional adjustments capture e.g., certain model imperfections (e.g. compression model adjustment for option portfolios, potentially larger liquidation costs (liquidity adjustment) for large and directional portfolios, and pro-cyclicality effects by means of portfolio-margining adjustments to ensure sufficient margin coverage also in times of stressed market conditions). 

For further information please visit Member Section - Deutsche Börse Group > Resources > ECC > ECC Prisma.

ECC Prisma for Commodities will cover all derivative products cleared by ECC. 

For the model parameters ECC currently provides the SPAN file. For the new model this will be replaced by the Transparency Enabler Files (TE files). These files are generally the same as those used by ECAG plus an extra TE file (WGFCT) containing the weighting factor. Member reports remain the same but the broadcasted content needs to be interpreted according to the new model. A new member report (CP043) will also be introduced.

The Cloud Prisma Margin Estimator (Cloud PME) will be ECC’s cloud-based solution for margin simulations under ECC Prisma for Commodities, ECC’s new margin methodology. 

The service will be free of charge and specifically tailored for end users who wish to simulate margin requirements for commodity derivatives. The Cloud PME is easy to use and will be accessible via any web browser’s GUI. Users may enter individual commodity derivatives positions directly into the GUI or upload entire portfolios in several formats. The resulting margin is directly available in the GUI and breakdowns into the individual margin components will be transparent. More advanced or technically adept users can also connect to the service via an API, allowing for a high degree of flexibility and automation. The Cloud PME will also be available for the simulation environment via GUI in order to make it possible to test enhancements coming with a release.

The initial version of ECC’s version of the Cloud PME is planned to be rolled out with R7 release 4.1 scheduled for August/September 2025.

During the "parallel phase" ECC will offer all participants "comparison reports" showing the margin numbers for both margin models. For the avoidance of doubt, until the official migration, the current SPAN-based margin numbers are relevant and any margin call is based on these numbers.

Additionally the Cloud PME can be used to recalculate initial margin.

For each “market” e.g. "German Power", i.e. on sub-portfolio level, a Liquidity Risk Component will be calculated as the 1-day VaR for that sub-portfolio scaled by a coresponding market dependent Liquidity Factor. The Liquidity Factor is a linear function depending on position size and market capacity. To reflect the portfolio composition, the total sum over all individual Liquidity Risk Comoponents is scaled down by a specific, portfolio dependent diversification  factor.

Dedicated risk and margin reports (CI0xx) will be available every ten minutes via the Common Report Engine (CRE) informing members about their current (near-time) exposures and provide certain aggregation levels from account level to collateral pool level. More details about the reports con be found in the "Report Manual" located in the member section (Member Section - Deutsche Börse Group). If clients want to receive any of these reports, they are invited to register themselves under clearing@ecc.de.

Generally all reports containing margin information are impacted but not in their syntax but rather the content: The current margin class SPAN is replaced by the Prisma Margin Class.

• Definition: DORA defines an ICT Service as digital and data services provided through ICT systems to one or more internal or external users on an ongoing basis (Art. 3(21) DORA).  
• Requirements: ICT Services provided by ICT third-party service providers to Financial Entities must comply with Art. 30 DORA.  
• Examples: Annex III of the Commission Implementing Technical Regulation 2024/2956 (the “ITS”) provides examples of ICT Services, focusing on the information needed for the register as per Art. 28(3) DORA.  
• Clarification: FAQs from the European Supervisory Authorities (ESAs) clarified that a service shall not be considered as an ICT Service if a Financial Entity is authorized to deliver such service. Consequently, any activities which are directly resulting from these authorizations would not constitute ICT Services. However, these FAQs have been partially withdrawn and the European Commission plans to clarify this through a Q&A with the support of the ESAs.

European Commodity Clearing AG (“ECC AG”) is authorized to operate as a central counterparty.  

In accordance with the EU COM Guidance ECC AG do not consider the core services (such as clearing) to be ICT services within the meaning of DORA. Clearing is not provided as an IT platform or software solution service. The aforementioned clearing activities are subject to a regulatory authorization requirement, but ECC does not offer clearing as PaaS, SaaS, IaaS solutions. 

Accordingly, we consider it not necessary to amend existing contractual arrangements in this respect.
We are closely monitoring the further development of the DORA legislation and the associated administrative practice. 

You can get in touch via dora-ecc@ecc.de. As reference, please mention your Member ID, and the service you are referring to.

It is one of our main goals to apply the highest security standards to protect our systems and ensure stable market and clearing environments.