Minutes of the London FXJSC Legal Sub Committee Meeting – 17 March 2026

Time: 2pm – 3.30pm | Location: Bank of England, Threadneedle Street, London, EC2R 8AH

The Chair (Sharon Blackman) opened the meeting, welcoming those online and in person.

Minute 2: Minutes of 24 November Legal Sub-Committee

The minutes of the meeting of 24 November 2025 were approved.

Minute 3: Look back / look forward: update on the regulatory framework impacting the FX market (Clifford Chance – Caroline Dawson)

The discussion focused on the impact of BMR on FX benchmarks, particularly in relation to non-EU FX rates.

The original EU regime captured a broad range of benchmarks and sought to prevent people from evading regulation by using non-EU benchmarks. To achieve this, it prohibited the use of a benchmark unless its administrator appeared on the benchmark register.

This has created practical challenges for non-EU benchmark administrators qualifying under the third-country regime.

A transitional period has been in place due to these difficulties; however, despite repeated extensions, the regime has not yet been fully implemented.

The latest extension is due to expire at the end of this year, with limited appetite for further extensions.

The EU is instead moving towards a narrower scope:

A specific exemption regime is emerging, with a number of benchmarks proposed for exemption, limited to benchmarks not administered by central banks.

Overall the revised approach may provide greater certainty for EU market participants where non-EU benchmarks are not significant or are exempt.