News & Analysis as of

Over The Counter Derivatives (OTC) Regulatory Reform

A&O Shearman

UK FCA finalises approach to ancillary activities test

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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

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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

ESRB And IOSCO Publish Final Reports Analysing Credit Default Swaps Market

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The European Systemic Risk Board (ESRB) has published a report analysing the credit default swaps (CDS) market, with a particular focus on single-name CDSs in terms of their market structure and current regulatory framework....more

A&O Shearman

Delegated regulation on identifying reference data for OTC derivatives published in OJ

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Commission Delegated Regulation (EU) 2025/1003 has been published in the Official Journal of the European Union (OJ), supplementing the EU Markets in Financial Instruments Regulation (MiFIR) as regards over-the-counter...more

A&O Shearman

FCA Handbook Notice 129

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The UK Financial Conduct Authority (FCA) has published Handbook Notice 129 which sets out changes to the classes of derivatives subject to the derivatives trading obligation (DTO), following policy statement PS25/2 published...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

Stikeman Elliott LLP

CSA Seek Comments on Enhanced OTC Derivatives Data Reporting Amendments

Stikeman Elliott LLP on

Proposed amendments are intended to reduce regulatory burden by aligning over-the-counter (OTC) derivatives data reporting requirements with international standards developed by the Committee on Payments and Market...more

Holland & Knight LLP

Congress Takes Up FDA Over-The-Counter (OTC) Drug Regulation Reform

Holland & Knight LLP on

On September 13, the U.S. House of Representatives Energy and Commerce Committee’s Subcommittee on Health held a hearing to examine draft legislation to create a new user fee program and completely revamp the review process...more

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