News & Analysis as of

Over The Counter Derivatives (OTC) HM Treasury

A&O Shearman

UK FCA finalises approach to ancillary activities test

A&O Shearman on

The UK Financial Conduct Authority (FCA) has published policy statement PS25/24 finalising its revised approach to the ancillary activities test (AAT). The AAT determines when non financial firms trading commodity derivatives...more

Katten Muchin Rosenman LLP

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

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...more

A&O Shearman

HMT consults on updating the UK's exemption framework for intragroup over-the-counter derivatives

A&O Shearman on

HM Treasury (HMT) has published a draft statutory instrument (SI), the Over the Counter Derivatives (Intragroup Transactions) Regulations 2026, for technical comment, alongside a policy paper. The proposed Regulations aim to...more

A&O Shearman

UK equivalence regulations for Swiss CCPs and margin for OTC derivatives not centrally cleared

A&O Shearman on

The OTC Derivatives Risk Mitigation and Central Counterparties (Equivalence) (Switzerland) Regulations 2025 have been laid before Parliament and published with an explanatory memorandum. The Regulations, made on 16 July,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Taking Stock of Commodity Derivatives Regulation in the UK and EU

In July 2021, HM Treasury published the Wholesale Markets Review consultation (WMR), which included proposals to reform the U.K.’s secondary markets framework. There was broad support for reforms to (a) modify the ancillary...more

A&O Shearman

HM Treasury Confirms Policy Approach on Wholesale Markets Review

A&O Shearman on

HM Treasury has published its consultation response to the Wholesale Markets Review, setting out summaries of responses received to its proposals and how changes will be progressed. There are certain areas that HM Treasury...more

Morgan Lewis

UK Commodity Derivatives Regime: FCA Not Enforcing Position Limits as HM Treasury Consults on Changes

Morgan Lewis on

The UK Financial Conduct Authority (FCA) announced on July 9 that, while changes to the scope of the UK commodity position limits regime are being consulted on, it will not take enforcement action against firms that breach...more

Hogan Lovells

HMT confirms no more open access for exchange-traded derivatives

Hogan Lovells on

On 5 May 2020, the HM Treasury confirmed that it plans to remove the open access regime for exchange-traded derivatives (ETDs), which is currently within the UK version of the Markets in Financial Instruments Regulation (UK...more

A&O Shearman

Draft UK Legislation to Onshore EMIR 2.2 Published for Feedback

A&O Shearman on

HM Treasury has published for feedback a draft statutory instrument to implement the revised provisions for CCPs in the European Market Infrastructure Regulation (known as EMIR 2.2.) into U.K. law once the Brexit...more

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