PS25/16: Margin requirements for non-centrally cleared derivatives: Amendments to BTS 2016/2251

Read PS25/16[1] 

What we are changing

This joint PRA/FCA Policy Statement contains amendments to Binding Technical Standards (BTS) 2016/2251, introducing:

• An indefinite exemption for single stock equity options and index options from the UK’s bilateral margining requirements.
• Amendments for legacy contracts for counterparties that fall under the Average Aggregate Notional Amount (AANA) threshold.
• Amendments to allow firms to align dates related to the AANA calculation with other jurisdictions. 

Who this is for

The publication is relevant to PRA-authorised banks, building societies and PRA-designated investment firms in scope of the margin requirements under the European Market Infrastructure Regulation (UK EMIR).

It is also relevant to all FCA solo-regulated entities and non-financial counterparties in scope of the margin requirements under UK EMIR.   

Next steps

The amendments to the BTS take effect on 27 November 2025, which is when the final technical standards instruments from the PRA and FCA come into force.

Background  

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

Single-stock equity options and index options were temporarily exempted from these requirements until 4 January 2026. In March 2025, we consulted on proposals (CP25/5[2]) to exempt these products indefinitely, as well as targeted changes to improve the process for exchanging margin, following industry feedback.  

Overall, respondents supported the changes, with some minor amends.