New UK intragroup derivatives rules aim to simplify EMIR compliance from 2027.
The United Kingdom’s implementation of the European Market Infrastructure Regulation – known locally as UK EMIR – has long provided a framework for clearing and margin obligations on over-the-counter (OTC) derivatives. Over the past years, market participants have repeatedly highlighted the administrative weight of the intragroup exemption machinery, prompting the Treasury to revisit the rules.
On 21 October 2026, the Treasury published the Over-the-Counter Derivatives (Intragroup Transactions) Regulations 2026. This final statutory instrument replaces the temporary provisions that were introduced under the Temporary Intragroup Exemption Regime (TIGER) and establishes a permanent, streamlined exemption structure for qualifying intragroup trades.
Permanent exemption structure and removal of outdated guidance
The new regulations introduce a permanent exemption regime that retains the core principles of the earlier temporary measures but eliminates the need for annual renewal applications. To qualify, counterparties must satisfy a set of conditions – such as maintaining a documented risk-management framework and ensuring that the transactions are truly intra-group – which are now codified in the freshly issued Binding Technical Standards (BTS).
In parallel, the Treasury has revoked a series of EMIR questions and answers (EMIR Q&As) that previously addressed the intragroup regime, thereby reducing regulatory uncertainty.
Revised notification timetable and streamlined Connect process
The transition to the new regime is scheduled to begin on 1 January 2027. All margin and clearing exemptions that were active immediately before that date will continue, provided the underlying conditions remain satisfied. This includes the exemptions that were temporarily granted under TIGER. Firms that wish to secure a fresh exemption before the start of 2027 are urged to submit their notifications by 5 December 2026 using the existing notification pathway described on the FCA website.
Notifications received between 5 December and 31 December should be directed to the FCA’s dedicated mailbox at [email protected]. The authority will engage with these applicants to clarify any transitional issues. From 1 January 2027 onward, every new request must be lodged through the upgraded Connect platform, which will host the streamlined notification workflow. Detailed instructions for the post-January process are outlined in Chapter 5 of the policy statement.
What counterparties need to do now
Entities subject to UK EMIR – including banks, asset managers and corporate treasuries – should begin a gap analysis against the new BTS. Key steps include confirming that internal policies capture the definition of an intragroup transaction, updating documentation to reflect the permanent exemption criteria, and testing the Connect interface ahead of the 1 January launch. Industry bodies, law firms and consultants are also encouraged to disseminate the changes to their members so that the overall market can adapt smoothly.
By consolidating the exemption framework and removing redundant guidance, the Treasury aims to lower compliance costs while preserving the systemic safeguards that EMIR was designed to deliver. Stakeholders that act promptly will benefit from a seamless transition and avoid any interruption to their derivative activities once the new regime becomes operational.
