Non-deliverable forward traders in the United Kingdom face potential exclusion from popular Asian currency fixings under HM Treasury’s proposed Specified Authorised Benchmark Regime. Replacing the unreformed EU Benchmark Regulation, the new UK regulatory framework threatens market access unless specific exemptions are granted for key offshore rates.
The Regulatory Collision Course in London
According to reporting from Risk.net and FX Markets, market participants trading non-deliverable forwards (NDFs) risk losing operational access to benchmark fixings for major Asian currencies.
While global jurisdictions modernize their regulatory rulebooks, the UK remains the only major economy maintaining an unreformed version of the EU’s Benchmark Regulation (BMR). HM Treasury has advanced plans to replace this legacy framework with the Specified Authorised Benchmark Regime (SABR). Here is the math: under SABR, regulatory oversight will concentrate exclusively on benchmarks where authorities identify risks of significant disruption to the UK financial system.
The Bottom Line
- Regulatory Divergence: HM Treasury’s proposed Specified Authorised Benchmark Regime (SABR) replaces the unreformed EU BMR, altering how offshore rates are classified in London.
Assessing the Scope of SABR and Offshore Fixings
Key offshore rates critical for settling Asian NDFs risk falling directly into the broad scope of the new regime. If these benchmarks fail to secure explicit exemptions, compliance mandates will effectively push them out of bounds for UK-domiciled entities.
| Regulatory Framework | Jurisdiction | Core Impact on NDF Fixings |
|---|---|---|
| Unreformed BMR | United Kingdom (Legacy) | Applies broad supervisory burdens across multiple foreign benchmarks without targeted carve-outs. |
| Specified Authorised Benchmark Regime (SABR) | United Kingdom (Proposed) | Limits regulation to benchmarks posing significant domestic disruption risks, threatening unexempted offshore rates. |
Navigating Compliance and Market Liquidity
If the UK’s benchmark rewrite proceeds without safeguarding key Asian NDF fixings, trading volume could migrate away from London toward jurisdictions with clearer regulatory harmonization.

Disclaimer: The information provided in this article is for educational and informational purposes only and does not constitute financial advice.