Streamlining the UK EMIR Intragroup Regime (Financial Conduct Authority)

Summary

• The Treasury published The Over-the-Counter Derivatives (Intragroup Transactions) Regulations 2026 on 21 October to establish a permanent and streamlined intragroup transaction regime.p.4
• The updated intragroup regime takes effect on 1 January 2027, and all exemptions applying immediately prior to this date will remain valid.p.6
• Counterparties seeking new intragroup margin or clearing exemptions prior to 1 January 2027 are encouraged to submit notifications before 5 December 2026.p.6
• The Temporary Intragroup Exemption Regime (TIGER) for counterparties transacting with non-equivalent overseas jurisdictions is scheduled to expire on 31 December 2026.p.7
• The framework reduces the notification period for intragroup margin exemptions from 3 months to 30 calendar days.p.8
• The 30-day notification period officially begins on the day after the FCA receives a complete notification.p.10

Key insights

1. The FCA policy statement confirms final Binding Technical Standards and revokes specific EMIR Q&As to streamline the UK EMIR Intragroup Regime.p.4
2. Counterparties seeking exemptions between 5 December 2026 and 31 December 2026 must contact the FCA directly to discuss transitional arrangements.p.6
3. UK EMIR provides exemptions from central clearing and bilateral margining for transactions between entities within the same consolidated group.p.7
4. Intragroup exemptions granted under TIGER will become permanent without requiring equivalence determinations for non-UK jurisdictions.p.8
5. Pairs of non-UK counterparties subject to UK EMIR requirements will become eligible for intragroup margin and clearing exemptions starting 1 January 2027.p.8
6. Counterparties will be able to submit a single notification on Connect covering multiple pairs of intragroup counterparties from 1 January 2027.p.10
7. Supplementary documentation required for intragroup margin notifications will be reduced, eliminating requirements to submit historical transaction data or contract copies unless specifically requested.p.15
8. Pairs of UK counterparties will no longer be required to notify the FCA to use an intragroup clearing exemption, aligning with margin exemption treatments.p.15