ISDA has published these Model Representations to facilitate use of the pass-through hedging exemption set out in Rule 10.2.14R and Rule 10.2.15R of the UK FCA Code of Market Conduct Handbook. The pass-through hedging exemption is an exemption available to financial firms from the position limits on commodity derivatives and comes into effect on 6 July 2026. The Model Representations allow parties to represent, either in the Schedule to an ISDA Master Agreement, in a separate side-letter, or in a Confirmation of a specific Transaction that each relevant Transaction facilitates hedging activity.