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ARTICLE · 27 NOVEMBER 2025

UK EMIR Update: Intragroup Exemption Consultations And Additional Q&As

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On 5 November 2025, HM Treasury (HMT) published a draft statutory instrument, the Over-the Counter-Derivatives (Intragroup Transactions) Regulations 2026 (draft SI), together with a policy note, and the UK Financial Conduct Authority (FCA) published a consultation paper (CP25/30).

United KingdomFinance and Banking
Carolyn Jackson
Carolyn Jackson
Ciara McBrien
Ciara McBrien
James Wells
James Wells
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On 5 November 2025, HM Treasury (HMT) published a draft statutory instrument, the Over-the Counter-Derivatives (Intragroup Transactions) Regulations 2026 (draft SI), together with a policy note, and the UK Financial Conduct Authority (FCA) published a consultation paper (CP25/30), each proposing significant reforms to the UKEuropean Market Infrastructure Regulation(EMIR) intragroup exemption framework for clearing and bilateral margin.

These developments follow the FCA and Bank of England's (BoE) finalisation on 31 October 2025 of technical EMIR reporting questions and answers (Q&As) addressing derivative reporting requirements.

For further information on recent developments to EMIR reporting requirements, please see our recent article available here.

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