On March 11, ISDA, the Global Foreign Exchange Division of the Global Financial Markets Association, UK Finance and the Loan Market Association responded jointly to a consultation from His Majesty’s Treasury on the future regulatory regime for benchmarks and benchmark administrators.

The associations support the HMT proposals to replace the existing UK Benchmark Regulation (BMR), which was onshored from the EU and has wide regulatory reach, with a regime that would regulate only those benchmarks and benchmark administrators that may pose systemic risks to UK financial markets.

Following reforms to the EU BMR that came into effect on January 1, 2026, the UK became the only jurisdiction with a benchmarks regime that regulates all benchmarks produced within the jurisdiction. Under the proposed new Specified Authorised Benchmarks Regime (SABR), HMT would designate benchmarks that meet specified criteria, and only designated benchmarks and their administrators would be regulated. In their response, the associations emphasize the need to ensure those criteria are not ambiguous and don’t lead to over-designation.

The HMT consultation will result in new legislation that repeals and replaces the UK BMR and delegates firm-facing requirements to the FCA. This consultation will be followed by an FCA consultation on the detailed firm-facing rules. A date has not yet been fixed for the FCA consultation.