CCP Margin Monitor · Issue #1

ICE Clear Credit (ICC) vs ICE Clear Europe (ICEU), Q4 2025 PQD

ICE publishes a quarterly clearing disclosure, per clearing house, under the CPMI-IOSCO Public Quantitative Disclosure (PQD) standard: default fund requirement, Cover-2 peak stress loss, and total initial margin required. This issue recomputes the delta between two of ICE's own clearing houses for the same quarter and attaches a hash-anchored receipt to the result. It does not audit whether either house's underlying disclosure is truthful, does not rank the two houses, and does not redistribute the disclosure documents themselves. Every number below is a computed derivation, cited back to its source field.

Derived, Never Mirrored Hash-Anchored Receipt Free, Issue #1 Methodology v1.0
🔒 This issue was computed offline from public disclosure documents. No personal data appears anywhere in this page or in the receipt below.
What this is not: this is not a determination that either clearing house's margin model is sound, not legal advice, not an audit, and not a submission to any authority. The comparator emits delta arithmetic and threshold flags only, never a "better/worse" ranking. ICC and ICEU are both ICE clearing houses reporting against the same PQD template for the same quarter, so this is the cleanest same-CCP, cross-division comparison the fixture currently supports.
Subject & Disclosure Period

ICE Clear Credit (ICC) · ICE Clear Europe (ICEU) · Q4 2025

Publisher: ICE (Intercontinental Exchange). Source: ICE Quarterly Clearing Disclosures, Q4 2025, ice.com/clearing/quarterly-clearing-disclosures. Skin-in-the-game of $343,000,000 is disclosed as a single total across all six ICE clearing houses, not broken out per house, so it is not scored per-division in this issue.

$4,798M
ICC default fund requirement
$3,706M
ICEU default fund requirement
24.55%
ICC Cover-2 / default fund
99.03%
ICEU Cover-2 / default fund
Source line (as published)ICCICEU
Default fund requirement$4,798,000,000$3,706,000,000
Cover-2 peak stress loss$1,178,000,000$3,670,000,000
Total initial margin required$57,855,000,000$60,751,000,000

Per the source disclosure, Cover-2 peak stress loss is the largest combined loss the CCP's stress-testing program would face from the default of its two largest clearing-member exposures; the default fund requirement is the CCP's own sizing of the mutualized default fund needed to cover it. Both figures come from the same Q4 2025 PQD template both houses publish.

Derivation

Delta, ratio, threshold

Computed by art-528-cross-ccp-pqd-comparator, the suite's cross-CCP PQD field comparator, run against the fields and threshold declared below. The kernel performs no lookups (zero-egress) and ships no live PQD feed of its own; every figure is this page's own declared input, pinned in the receipt as fixture data manually transcribed from ICE's published PDF.

FieldDelta (ICEU − ICC)Delta %
Default fund requirement−$1,092,000,000−22.76%
Cover-2 peak stress loss+$2,492,000,000+211.55%
Total initial margin required+$2,896,000,000+5.01%
Threshold checkDeclared ruleICCICEU
Cover-2 / default fund requirement≥ 40% of default fund requirement24.55%, no breach99.03%, breach
What the numbers say, and don't ICEU's Cover-2 stress loss sits at 99.03% of its own default fund requirement, against 24.55% at ICC, for the same quarter and the same disclosure template. That is a delta in how tightly each house's stress scenario tracks its fund sizing, not a soundness judgment. A CCP's default fund is one layer of a multi-layer waterfall (initial margin, the fund itself, CCP capital, further assessments); this issue checks one ratio inside that waterfall, nothing else.
What this issue does not cover FICC (DTCC's GSD/MBSD/NSCC divisions) publishes a differently-shaped PQD field set: backtest coverage percentage and largest single-day margin deficiency, not the fund-sizing/stress fields ICE discloses. A cross-CCP FICC-vs-ICE run against these same fields returns every field PQD_FIELD_UNAVAILABLE on one side, honestly, rather than an interpolated or fabricated figure. That comparison is deferred to a future issue that compares FICC divisions against each other on their own disclosed fields, rather than forcing a mismatched comparison into this one.
Receipt

The six fields, and the full artifact

FieldValue
SubjectICE Clear Credit LLC (ICC) and ICE Clear Europe Limited (ICEU), both ICE clearing houses
Disclosure periodICE Quarterly Clearing Disclosures, Q4 2025
Source field(s)default_fund_requirement_usd, cover2_peak_stress_usd, total_im_required_usd
Computed value3 fields fully available both sides; default fund delta −22.76%, Cover-2 delta +211.55%, total IM delta +5.01%; threshold breach on entity_b (ICEU) only
execution_hashbb9a8366f9279a832f8963d3c76b7ce728f05e2be68cd9edbc369c0a12577e77
verify_urlainumbers.co/chaingraph/verify.html , paste the artifact below to replay the hash offline

Computed by art-528-cross-ccp-pqd-comparator v1.0.0, tool_id-pinned in the artifact. Any third party can run this kernel against the same policy_parameters below and reproduce the identical execution_hash.

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Versioning

Computed under Methodology v1.0

This issue was computed under Benchmark Series Methodology version v1.0 (2026-08-03). If a later methodology revision changes the derivation formula, this issue's figures stay dated to v1.0 rather than being silently re-narrated as wrong. No cadence SLA and no coverage percentage are claimed for the series: this is one dated issue, not a promise of the next one's timing.

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