For groups subject to the UK derivatives regime, there has been little regulatory change for some time. As we approach the midpoint of 2025 the position is likely to stay the same for the rest of the year. Although a number of consultations are expected from the UK’s PRA and FCA on the UK’s derivatives regime (“UK EMIR”), these are expected to result in technical refinements rather than wholesale change.
For groups subject to the EU regime (“EU EMIR”), the changes brought about by the “EMIR 3” regulation and directive at the end of 2024 may have required some technical changes already, and further changes may result from finalisation of additional technical standards. The impact of these changes is likely to be muted for groups which are formed of “NFC-” entities. However, for entities near the borderline of the NFC- classification, the full impact of the changes will only become apparent when the detail of those technical standards is finalised.
This briefing summarises the recent and pending developments in these two regimes, as well as areas of divergence between them. These areas and the possibility of further divergence should be monitored closely as and when we hear further policy updates from the regulators.
Source and credits: https://www.slaughterandmay.com/insights/new-insights/what-do-corporate-treasurers-need-to-know-about-eu-emir-and-uk-emir-as-we-approach-the-midpoint-of-2025/