CP23/16 - Margin requirements for non-centrally cleared derivatives: Amendments to BTS 2016/2251

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Consultation closes

The Prudential Regulation Authority (PRA) and FCA are consulting on changes to the UK bilateral margining requirements under the UK version of the European Market Infrastructure Regulation (UK EMIR).

Read CP23/16

Why we are consulting

These proposals aim to:

  • extend the temporary exemption for single-stock equity options and index options from the UK bilateral margining requirements from 4 January 2024 until 4 January 2026, and
  • set out the PRA and FCA’s proposed approach to pre-approving bilateral initial margin models

Who this is for

The proposals will apply to:

  • PRA-authorised firms that are financial counterparties for the purposes of Article 2 of UK EMIR
  • all FCA solo-regulated entities and non-financial counterparties in scope of the margin requirements under UK EMIR

Next steps

This consultation closes on Wednesday 18 October 2023.

PRA-regulated firms should send their comments or questions about these proposals to [email protected] and FCA firms to [email protected].   

After considering the responses, we will submit the updated technical standards to the Treasury for approval. If this is given, we will make and publish the amendments to the technical standards for the firms we regulate. At the same time, we will confirm the approach for model pre-approval for initial margin models. 


Under UK EMIR, firms are required to exchange initial and variation margin on non-centrally cleared OTC derivatives.

Single-stock equity options and index options are exempted from these requirements until 4 January 2024. This consultation proposes extending these temporary exemptions until 4 January 2026 so the PRA and FCA can undertake deeper analysis to develop a permanent UK framework for these products.

Industry has also asked the PRA to clarify the UK’s approach to supervising the pre-approval of initial margin requirements. This consultation aims to provide clarity to industry in this respect.