{
  "tool_id": "art-581-emir3-simm-approval-scope-classifier",
  "kernel_id": "art-581-emir3-simm-approval-scope-classifier",
  "display_name": "EMIR 3 SIMM Approval-Scope Classifier",
  "tool_version": "1.0.0",
  "mandate_type": "compliance_mandate",
  "purpose": "Classifies which EMIR 3 initial-margin model-approval obligations apply to a caller-declared counterparty profile across four items: prior competent-authority (NCA) authorisation before using or changing an initial-margin model under Article 11(12a) (inserted by Regulation (EU) 2024/2987); EBA central validation of a pro forma model's elements and general aspects, also under Article 11(12a), for the ISDA SIMM case; the recurring end-March annual application-data update to the home NCA for an already-authorised SIMM user, under the Article 11(15) supervisory-procedure process; and the 2026 EBA validation-system onboarding window published for SIMM applicants, open through end-August 2026. Each obligation resolves to IN_SCOPE, OUT_OF_SCOPE, or INDETERMINATE, and INDETERMINATE covers every case where a required fact -- a declared home competent authority, or a model-status distinction between a new application and an already-authorised model -- was not supplied; none is guessed toward a passing verdict. Carries zero ISDA SIMM methodology content: no risk weight, correlation, bucket, or sensitivity math, and no reproduction of any ISDA document. Cites EMIR Article 11(12a) and Article 11(15) as amended by Regulation (EU) 2024/2987, re-verified against EUR-Lex and EBA's published process at build; the implementing RTS and Guidelines on initial-margin model authorisation were at public-consultation stage (17 March - 17 June 2026) and not yet finalised as of the build date, stated plainly in-page. Distinct from art-576's Active Account Requirement classifier -- this is the initial-margin model-approval track, not the clearing-obligation track. Stated boundary: this is not legal advice, expresses no ISDA endorsement, and does not perform any methodology-level verification of an actual initial-margin model -- that omission is deliberate and disclosed in-page.",
  "control_description": "Classifies which EMIR 3 initial-margin model-approval obligations apply to a caller-declared counterparty profile across four items: prior competent-authority (NCA) authorisation before using or changing an initial-margin model under Article 11(12a) (inserted by Regulation (EU) 2024/2987); EBA central validation of a pro forma model's elements and general aspects, also under Article 11(12a), for the ISDA SIMM case; the recurring end-March annual application-data update to the home NCA for an already-authorised SIMM user, under the Article 11(15) supervisory-procedure process; and the 2026 EBA validation-system onboarding window published for SIMM applicants, open through end-August 2026. Each obligation resolves to IN_SCOPE, OUT_OF_SCOPE, or INDETERMINATE, and INDETERMINATE covers every case where a required fact -- a declared home competent authority, or a model-status distinction between a new application and an already-authorised model -- was not supplied; none is guessed toward a passing verdict. Carries zero ISDA SIMM methodology content: no risk weight, correlation, bucket, or sensitivity math, and no reproduction of any ISDA document. Cites EMIR Article 11(12a) and Article 11(15) as amended by Regulation (EU) 2024/2987, re-verified against EUR-Lex and EBA's published process at build; the implementing RTS and Guidelines on initial-margin model authorisation were at public-consultation stage (17 March - 17 June 2026) and not yet finalised as of the build date, stated plainly in-page. Distinct from art-576's Active Account Requirement classifier -- this is the initial-margin model-approval track, not the clearing-obligation track. Stated boundary: this is not legal advice, expresses no ISDA endorsement, and does not perform any methodology-level verification of an actual initial-margin model -- that omission is deliberate and disclosed in-page.",
  "declared_inputs": [],
  "declared_outputs": [],
  "kernel_digest": "sha256:05b8c0c228321335e7ba3d1133c961b3ba2aebcd9e92f1735833b892d78170ce",
  "trust_label": "independently verified: zkVM execution proof (risc0/groth16-bn254)",
  "data_vintage": "2026-08-07",
  "last_validated": "2026-08-07",
  "conformance_fixtures_vendored": true,
  "compute_proof_ready": "ready",
  "wave": 97,
  "source_url": "https://ainumbers.co/chaingraph/art-581-emir3-simm-approval-scope-classifier.html",
  "generated_at": "2026-08-15T11:12:17.704Z"
}