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Taking the pulse of ISDA’s CDM: 3 areas to monitor

<p><br> <span class="small">September 30, 2025</span></p>
Taking the pulse of ISDA’s CDM: 3 areas to monitor
<p><b>Adoption of the emerging standard for derivatives trading is off to a slow start. We sort out what you need to watch for—and when it’s time to make your move.</b></p>
<p>When it comes to shaping the future of derivatives markets, no organization has more influence than the International Swaps and Derivatives Association (ISDA). With its common domain model (CDM), ISDA is pushing for an ambitious shift: an open, standardized blueprint that represents trades in a consistent, machine-readable format. To make that happen, CDM will need to replace today’s patchwork of systems with a universal language for data, events and processes, especially for complex over-the-counter derivatives like futures, options and swaps.</p> <p>ISDA <a href="https://www.isda.org/2018/06/05/isda-publishes-digital-iteration-of-the-common-domain-model/" target="_blank">opened</a> the CDM for testing by members way back in 2018. But as happens with many new standards, the mandate is so far non-binding and, as a result, off to a slow start.</p> <p>For one thing, with no immediate cost savings <i>or regulatory mandate</i>, <i>organizations find it hard to justify the time and cost</i>—especially given their heavy investment in existing infrastructure<i>.</i></p> <p>For another, they worry about integration, which can be costly and complex. Re-architecting data models and lifecycle events means reworking internal systems, training teams, and plenty of testing.</p> <p>Moreover, organizations impacted by CDM already have plenty on their plates with mandated initiatives like ISO 20022 migration and new regulatory requirements for trade reporting. While CDM is gaining traction in certain use cases (collateral, margin, clearing), the lack of adoption across all counterparties limits the benefit of being early. As a result, CDM keeps falling off the to-do list.</p> <h4>What to watch for</h4> <p>But CDM is here to stay, and it's important to keep a close eye on the standard’s progress. In derivatives, interoperability is the name of the game—no institution wants to be the one still using custom data models when the rest of the ecosystem has adopted CDM.</p> <p><i>Here are three areas for organizations to monitor as they consider when to make the move to CDM.</i></p> <ol> <li><b>Regulatory alignment or mandate.</b> When <i>regulators signal CDM as the preferred or required reporting format, it becomes a must-have—not a nice-to-have. G</i>lobal regulatory bodies like the U.S. Commodity Futures Trading Commission and Japan’s Financial Services Agency are <a href="https://www.finos.org/press/from-finos-member-jscc-global-standardization-of-regulatory-reporting-leveraging-drr-cdm" target="_blank">increasingly looking</a> at CDM as a foundation for standardized trade and margin reporting.<br> <i><br> When to make your move:</i> Companies will need to act quickly if CDM adoption becomes the path to regulatory compliance, particularly under the <a href="https://www.youtube.com/watch?v=RrCL0yCz-0s\&amp;t=12s" target="_blank">Digital Regulatory Reporting initiative</a>. There’s a big benefit to not waiting until CDM is mandated: Early adopters have a voice in shaping how the standard is implemented for their region or asset class, which is a strategic advantage.<br> <br> </li> <li><b>Client or market pressure.</b> CDM works in a network economy model: the benefits accrue only if everyone in your ecosystem is adopting and using it. <i>When major clients or central counterparties (CCPs) shift to CDM, no organization can afford to be left behind.<br> <br> When to make your move:</i> If CCPs or global banks that provide access to derivatives clearing—think J.P. Morgan, Goldman Sachs or Citigroup—begin to require CDM compatibility, you’ll need to adhere to the standard to remain competitive. The upside? CDM adoption positions you as a partner of choice for modern post-trade services. The move to real-time settlement, or T+0, is on, and by standardizing data, events, and processes, CDM paves the way for an organic, seamless system built on distributed ledgers, smart contracts and real-time settlement.<br> <br> </li> <li><b>Operational efficiency and long-term cost reduction.</b> <i>CDM offers a compelling path to reduce duplication, manual work and reconciliation headaches. </i>Right now, players in derivative trades maintain multiple interfaces and message formats, which acts as a major drag on efficiency. CDM standardizes data models and lifecycle event logic across internal systems and counterparties—so there are fewer reconciliation breaks and cleaner audit trails.<br> <i><br> When to make your move:</i> If more than 50% of your transaction volume comes from institutions that are adopting CDM, the time to move is now. That’s because CDM standardizes process, validation, and mapping—it impacts nearly the entire tech stack. In three to five years, when the market is expected to move to smart contracts and digital ledgers, you’ll already be there.</li> </ol> <p>CDM adoption may be slower than anticipated, but it is inevitable. Forewarned is forearmed.</p> <p>&nbsp;</p>
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Kishore K Premkumar

Portfolio Head, Cognizant

<p>Kishore K Premkumar is Portfolio Head at Cognizant, bringing over 27 years of global leadership experience in technology and professional services. He has advised leading financial services institutions on navigate changing regulations and market dynamics, with experience spanning strategy and large-scale initiative that reimagine the operating model. Kishore is passionate about working with executives to define and navigate the future of financial institutions in ways that enhance efficiency, resilience, and customer experience.</p>
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Deepanker Venkatesh

Partner, consulting

<p>Deepanker Venkatesh is the head of Capital Markets Consulting for North America for Cognizant. For more 20 years, he has advised capital markets firms across multiple geographies spanning Asia, Europe and the Americas. Deepanker works with senior banking executives and helps them stay competitive and navigate the next.</p>
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