This Practice Note tracks divergence between European Market Infrastructure Regulation (EU) 648/2012 (EU EMIR) and Assimilated Regulation (EU) 648/2012 (UK EMIR).
How to use this Practice Note
This Practice Note can be used as a navigation aid when studying the provisions of Assimilated Regulation (EU) 648/2012 (UK EMIR), by providing a comparison with the corresponding provisions of Regulation (EU) 648/2012 (EU EMIR) regime. Set out below are links to all the Articles and Annexes in UK EMIR and EU EMIR respectively. Each part below provides information on:
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the relevant Articles and Annexes as they currently stand, including:
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the most recent changes made, the date they were made, and details of the implementing/amending/repealing legislation
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proposed reforms to certain Articles
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a brief summary of the points of divergence (ie how the relevant Article or Annex has evolved in the UK and/or the EU since 31 December 2020, being the end of the Brexit transition period)
The degree of variance between the regimes is signposted as follows:
Indicator | Definition(s) |
indicates that the |
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