EU EMIR Clearing Thresholds Revised from 10 November 2026, Creating UK-EU Regime Divergence

New EU EMIR clearing thresholds and revised calculation methodologies took effect on 10 November 2026. ESMA consulted on the proposed amendments in April 2025 and published its Final Report in February 2026. ESMA expects most counterparties to retain their existing clearing classification under the revised thresholds, but market participants with large uncleared positions may move from a "-" to a "+" classification. No corresponding changes are currently expected under UK EMIR, meaning the revised EU regime creates a significant divergence between the UK and EU regimes, with direct implications for market participants operating across both jurisdictions.