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As of mid-2025, the regulatory landscape for derivatives regimes in the UK and EU presents a contrast:
For groups subject to the UK derivatives regime (UK EMIR):
* Little Change Expected: The position is largely stable, with minimal significant regulatory shifts anticipated for the remainder of 2025.
* Technical Refinements: While the UK’s Prudential Regulation Authority (PRA) and Financial Conduct Authority (FCA) are expected to issue consultations on UK EMIR, these are primarily aimed at technical refinements rather than comprehensive overhauls.
For groups subject to the EU regime (EU EMIR):
* “EMIR 3” Impact: The “EMIR 3” regulation and directive, which came into force at the end of 2024 (specifically December 24, 2024, with some provisions effective upon finalization of technical standards), have already necessitated some technical adjustments.
* Further Changes from Technical Standards: Additional changes are likely as further technical standards are finalized.
* Muted Impact for “NFC-” Entities: For groups primarily composed of “NFC-” (Non-Financial Counterparty below the clearing threshold) entities, the immediate impact of EMIR 3 is expected to be muted.
* Uncertainty for Borderline NFC Entities: However, for entities nearing the “NFC-” classification borderline, the full implications of EMIR 3 will only become clear once the detailed technical standards are finalized. These standards will be crucial in defining new clearing thresholds and criteria for risk-reducing derivatives, which could significantly alter their obligations.
In essence, while the UK is maintaining a steady course with minor adjustments, the EU derivatives landscape is undergoing more material changes due to EMIR 3, with particular implications for how non-financial counterparties are classified and regulated.

Video courtesy of First Bank of Nigeria

Video courtesy of First Bank of Nigeria