libor transition

Timeline

The following is a timeline of key events. The working groups listed on our "Sources of information" page publish more detailed timelines for their respective currencies.

Timeline

Expiry of third-country transitional provisions under UK Benchmarks Regulation

Discontinuation of one-month, three-month and six-month synthetic US Dollar LIBOR

Discontinuation of three-month synthetic Sterling LIBOR

Expiry of third-country transitional provisions under EU Benchmarks Regulation (subject to possible extension to December 31 2025)

Publication of the overnight and 12-month US Dollar LIBOR settings currently published by ICE Benchmark Administration (IBA) will cease immediately after 30 June 2023. Also immediately after 30 June 2023, the 1-month, 3-month and 6-month US Dollar LIBOR settings will no longer be representative and representativeness will not be restored (FCA announcement 5 March 2021)

US Adjustable Interest Rate (LIBOR) Act enters into force

Critical Benchmarks (References and Administrators' Liability) Act 2021 enters into force

26 LIBOR benchmark settings ceased immediately after 31 December 2021. Also immediately after 31 December 2021, the 1-month, 3-month and 6-month Japanese Yen LIBOR settings and the 1-month, 3-month and 6-month Sterling LIBOR ceased to be representative of their underlying market (FCA announcement 5 March 2021) and continue in synthetic form for a limited time only

Cut-off date for new issuance of GBP LIBOR non-linear derivatives (except for risk management of existing positions) | ARRC-recommended cut-off date for new issuance of US Dollar LIBOR loans and derivatives

Cut-off date for issuance of new Sterling LIBOR loans, bonds, securitisations and linear derivatives (except for risk management of existing positions) | FCA announces the dates on which the LIBOR rates will either cease to be provided or cease to be representative of their underlying market | ISDA spread adjustment fixes for all LIBOR rates

EU Benchmark Regulation amended to empower the European Commission to mandate the use of a designated replacement rate for LIBOR in a broad range of contracts and financial instruments

ISDA Supplement 70 to the 2006 ISDA Definitions and ISDA 2020 IBOR Fallbacks Protocol become effective | ICE Benchmark Administration Limited (IBA) announces launch of a series of benchmark Term SONIA Reference Rates

ARRC-recommended cut-off date for new issuance of US Dollar LIBOR floating rate notes | ICE Benchmark Administration Limited (IBA) consults on proposed LIBOR cessation dates | FCA consults on proposed use of anticipated new powers under the UK Benchmarks Regulation

UK legislation proposed (The Financial Services Bill 2019-21) to amend the UK Benchmarks Regulation to ensure an orderly wind-down of LIBOR | New York state legislation (based on the ARRC's April 2020 draft legislation) proposed to introduce statutory provisions into the Uniform Commercial Code to apply on discontinuation of loss of representativeness of US Dollar LIBOR.

Working Group on Sterling RFRs publishes recommendation of the use of the historical five-year median spread adjustment methodology when calculating the credit adjustment spread which should be applied to any relevant SONIA rate chosen or recommended to replace GBP LIBOR

Bank of England begins publishing a daily SONIA Compounded Index

Bloomberg Index Services Limited (BISL) begins calculating and publishing adjusted RFRs (compounded in arrears), the spread adjustment and the ‘all in’ IBOR fallback rates for a wide range of IBORs across various tenors including EURIBOR, Euro LIBOR, HIBOR, Sterling LIBOR, Swiss franc LIBOR, Euroyen TIBOR, Yen LIBOR, Yen TIBOR and US Dollar LIBOR.

US Alternative Reference Rates Committee (ARRC) announces agreement on a spread adjustment methodology for cash products referencing USD LIBOR

US Alternative Reference Rates Committee (ARRC) publishes a proposal for New York State legislation to provide a commercially realistic solution for "tough legacy" contracts | New York Fed (as administrator of the Secured Overnight Financing Rate (SOFR)) begins publishing 30-, 90-, and 180-day SOFR Averages as well as a SOFR Index

EONIA becomes €STR plus a spread for a transition period from the first publication date of €STR on 2 October 2019 until the end of 2021

Administrator of EURIBOR, the European Money Markets Institute (EMMI) announces EURIBOR has obtained authorisation under the EU Benchmarks Regulation using a new hybrid methodology which EU regulators regard as robust, resilient and transparent

US Alternative Reference Rates Committee (ARRC) publishes recommended contractual fallback language for US Dollar LIBOR denominated floating rate notes

ISDA Benchmarks Supplement published

US Alternative Reference Rates Committee (ARRC) publishes guiding principles for the development of fallback language for new financial contracts for cash products

The European Money Markets Institute concludes that EONIA unlikely to comply with Benchmarks Regulation

The majority of provisions of the EU Benchmarks Regulation come into force, subject to transitional provisions

FCA announces agreement from panel banks for sustaining LIBOR until the end of 2021 but that beyond this date the FCA will no longer use its powers to sustain LIBOR

The Working Group on Sterling Risk-Free Reference Rates recommends SONIA as Sterling alternative

The EU Benchmarks Regulation published in the Official Journal

The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to.
Readers should take legal advice before applying it to specific issues or transactions.