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Expanding the Common Domain Model (CDM): New Frontiers in Financial Standardisation

Written by Marc Gratacos | Jul 16, 2025 10:30:00 AM

The implementation of the Common Domain Model (CDM) brings significant benefits to the efficiency and accuracy of meeting regulatory compliance, but the benefits of this powerful framework do not stop there. 

Smart businesses today are working out how to use CDM to its absolute fullest, to generate other efficiencies which are giving them a competitive edge. As co-creators of the CDM framework, we know that it represents a scalable and flexible foundational layer on which other efficiencies can be established.

The CDM Framework was initially developed by the International Swaps and Derivatives Association (ISDA) to standardise the representation of derivatives data. Now, under the Fintech Open Source Foundation (FINOS) umbrella, CDM has evolved into a pivotal framework for modelling financial transactions across the industry. What began as an initiative focused on standardising Over-the-Counter (OTC) post-trade events has grown to encompass an ever-wider set of use cases, reflecting the needs of a more integrated, digital, and automated financial ecosystem.

From Derivatives to Full Lifecycle Standardisation

The CDM provides a machine-readable, unambiguous, and extensible blueprint for how financial products, events, and processes are structured and executed. Its success in enabling consistent regulatory reporting through the ISDA Digital Regulatory Reporting (DRR) initiative has demonstrated the power of a shared domain model to reduce complexity, improve data quality, and enhance automation.

Building on this foundation, the CDM is now expanding into several new and strategically important areas:

Tokenisation

As the financial industry embraces blockchain and distributed ledger technologies, tokenisation of traditional assets has emerged as a key innovation. At the beginning of 2023, ISDA published the ISDA Digital Assets Derivatives Definitions, providing a legal framework for privately negotiated derivatives transactions referencing digital assets, specifically, non-deliverable forwards and options on Bitcoin and Ether. This was an important step to standardise trade confirmation for these products and their implementation as smart contracts.

In addition, a new CDM Digital Assets Working Group was recently created within FINOS to take charge of building the support for tokenised financial instruments and processes in CDM, ensuring that digital assets are interoperable with existing infrastructure and follow standardised event processing rules. This allows for consistent treatment of tokenised bonds, equities, or derivatives within both traditional and digital finance platforms.

Physical Risk

The CDM is expanding to include Physical Risk coverage, led by the CDM Physical Risk Working Group. This open-source initiative aims to help the financial system integrate physical climate risk into core operations. As climate events become more frequent and severe, physical risk is shifting—from a future concern to a current driver of value, from an unquantified threat to a tradable asset, and from a peripheral issue to a key factor in banking stability. With rising insurance costs and reduced coverage, the group’s goal is to enable scalable, cost-effective tools—such as physical risk swaps—to support institutions in managing regional hazard exposure and building long-term resilience.

Standard Schedule for Initial Margin

In the context of uncleared derivatives, calculating Initial Margin (IM) is essential for mitigating counterparty credit risk. While ISDA’s Standard Initial Margin Model (SIMM) provides a risk-sensitive model for calculating IM, many institutions opt for the simpler ‘Standard Schedule’ approach, especially for less complex portfolios or where regulatory exemptions apply. The CDM now has robust support for  ‘Standard Schedule’, including modelling of the data inputs, thresholds, and calculation logic directly within the model. Additional support for Mark-to-Market (MTM) valuations is currently being developed.  This integration helps streamline operations, enhances transparency, and facilitates automation of IM processes without the need for external calculation engines.

Collateral Management

Collateral flows and their management are core components of post-trade processes. CDM's expanding coverage includes the detailed modelling of collateral agreements, asset movements, margin schedules, and dispute resolution workflows. With CDM, firms can achieve more automated and auditable collateral lifecycle management while supporting interoperability between custodians, clearing houses, and counterparties. Collateral vendors have already started implementing CDM, initially as their API standard interface for their services.

Product and Event Modelling

A core strength of the CDM has always been its event-driven approach to transaction lifecycles. Recent developments further refine how products are defined (e.g., swaps, options, repos) and how events are qualified and processed (e.g., exercises, partial terminations, novations).

In the near future, we expect the model will be expanded to better support structured and complex financial products, such as callable swaps, equity-linked derivatives, and multi-leg structured trades. This will provide a more flexible and accurate representation of sophisticated instruments and their lifecycles. Additionally, the business event coverage is being broadened to capture a wider range of real-world scenarios, including corporate actions, lifecycle events for structured finance, and nuanced margining workflows. These enhancements support more accurate downstream processing, compliance monitoring, and risk analytics, ensuring CDM can model the full breadth of market activity.

Product and Event Qualification

Beyond simple modelling, the CDM now supports both product qualification and event qualification — mechanisms to classify and validate products and business events against predefined rules and criteria.

Product qualification ensures that a transaction’s structure complies with regulatory, operational, or business-specific guidelines. This is particularly important for initiatives like ISDA Digital Regulatory Reporting (DRR), where the accurate classification of instrument types (e.g., interest vs. equity) determines reporting paths.

Event qualification, on the other hand, validates the conditions and structure of lifecycle events. It ensures, for example, that a termination event adheres to agreed contract terms, or that a margin call meets the necessary threshold logic. These qualification features enable smarter automation, fewer exceptions, and stronger auditability across the transaction lifecycle.

A Foundation for the Future

With its growing adoption across market participants, vendors, and regulators, the Common Domain Model is becoming the shared language of finance. As coverage expands into tokenisation, collateral, and margin management, the CDM reinforces its role as a foundational layer for interoperable, efficient, and scalable financial infrastructure.

The continued success of CDM will depend on the community's collaboration—across sell-side, buy-side, infrastructure providers, and standards bodies. Together, we can ensure that innovation and standardisation go hand-in-hand in building a resilient and transparent financial future.