We have seen more than one change of date under EMIR over the last 2 weeks, including both trade reporting and clearing.

On the trade reporting side, we saw the first reporting date for interest rate swaps and credit default swaps, being set as the 23rd September, rather than “earliest 1st July”.

Then a couple of days ago we saw a footnote on the official timetable on the ESMA EMIR page, saying that the first TR registrations “were not expected” until August. If this expectation is met, then the first reporting date would not be until 3 months after that, i.e. November.

However, just because it is expected, does not mean that it will happen. So the possibility exists for earlier reporting, although this is unlikely.

A further question, that is of more relevance to the energy industry is whether the second date, when commodity derivatives need to be reported, will remain on the 1st Jan 2014.

So far there has been no official sign of it moving, will the ESMA dates staying at 1st January.

However, if the first date is in November, particularly in late November, it is hard to see how the January date can hold.