UK EMIR: UK grants CCP equivalence to key overseas jurisdictions
On 13 July 2026, HM Treasury laid before Parliament The Central Counterparties (Equivalence) Regulations 2026, granting UK EMIR equivalence to central counterparty (CCP) regulatory frameworks in key overseas jurisdictions. The Regulations enter into force on 3 August 2026.
The equivalence determinations are a precondition for individual CCPs in those jurisdictions to apply for Bank of England recognition under UK EMIR. Once recognised, a CCP will be able to provide clearing services to UK entities subject to the UK EMIR clearing obligation.
The Regulations will enable CCPs that are currently relying on the UK's temporary CCP recognition regime (TRR) to apply for permanent recognition before the TRR expires on 31 December 2027.
The Regulations cover certain CCPs regulated by:
The full table of specified overseas jurisdictions, relevant regulatory authorities and specified CCPs is replicated in the Annex.
From 3 August 2026, CCPs in newly equivalent jurisdictions may apply for Bank of England recognition under UK EMIR. Once recognition has been granted, they will be able to provide clearing services to UK entities under the recognition framework, subject to ongoing compliance with the recognition conditions.
In light of the future expiry of temporary recognitions under the TRR, market participants will welcome the certainty provided by the Regulations and, when granted, Bank of England recognition of key overseas CCPs.
Further equivalence determinations for additional overseas CCP regimes may follow in due course.
|
Specified overseas jurisdiction |
Relevant regulatory authority |
Specified CCP |
| Australia |
Australian Securities and Investments Commission and the Reserve Bank of Australia |
A CCP that is established in Australia which is regulated by the Australian Securities and Investments Commission and the Reserve Bank of Australia as an approved licensed domestic clearing and settlement facility |
| Hong Kong |
Securities and Futures Commission |
A CCP that is established in Hong Kong which is authorised by the Securities and Futures Commission as a recognised clearing house |
| India |
Securities and Exchange Board of India |
A CCP that is established in India which is regulated and supervised as a recognised clearing corporation by the Securities and Exchange Board of India |
| India | International Financial Services Centres Authority |
A CCP that is established in India which operates as a recognised clearing house and is regulated and supervised by the International Financial Services Centres Authority |
| Japan |
Japanese Financial Services Authority |
A CCP that is established in Japan which is licensed and supervised by the Japanese Financial Services Authority |
| Japan |
Ministry of Agriculture, Forestry and Fisheries and Ministry of Economy, Trade and Industry |
A CCP that is established in Japan which is licensed and supervised by the Ministry of Agriculture, Forestry and Fisheries and Ministry of Economy Trade and Industry |
| South Africa |
Financial Sector Conduct Authority, the Prudential Authority and the South African Reserve Bank |
A CCP that is established in South Africa which is licensed and supervised by the Financial Sector Conduct Authority, the Prudential Authority and the South African Reserve Bank as a clearing house. |
| United Arab Emirates |
Capital Market Authority |
A CCP that is established in the United Arab Emirates which is licensed to undertake central clearing activities and is regulated by the Capital Market Authority |
| United Arab Emirates |
Dubai Financial Services Authority |
A CCP that is established in the United Arab Emirates which operates as a clearing house in or from the Dubai International Financial Centre and is regulated and supervised by the Dubai Financial Services Authority as an authorised market institution |
| United States of America |
Securities and Exchange Commission |
A US-established SEC-registered CCP* |
The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to.
Readers should take legal advice before applying it to specific issues or transactions.