PS26/21: Streamlining the UK EMIR Intragroup Regime

For compliance teams at counterparties subject to UK EMIR, the practical focus is confirming which intragroup transactions fall within the revised exemption, updating policies, trade documentation and controls, and withdrawing reliance on the EMIR Q&As that the FCA has revoked. The changes should reduce ongoing documentation and compliance friction for intragroup hedging, but firms must read PS26/21 alongside the Treasury’s final statutory instrument to capture commencement and transitional detail. Legal, compliance and front-office teams should coordinate a gap assessment, refresh intragroup onboarding and evidence packs, and train relevant staff so that reduced burdens do not create misapplication or record-keeping risk.

Firms should also monitor for any further FCA or Treasury implementation guidance before changing live arrangements.