The UK Financial Conduct Authority have updated their page on EMIR trade reporting here.

Some interesting points:

• The first reporting date (for IDS and CDS) is on 23rd Sept.
• They still expect the rest of the trades to be reported in January.
• For trades outstanding on the reporting date, that were entered into after 16th August 2012, there are 90 days to report.
• For other trades that were struck after 16 August 2012, there are 3 years to report.
• They don’t say anything on trades struck before 16th August but that were still outstanding afterwards.

It is interesting to note that although the first reporting date is now nearly 3 months after when it could be (1st July), the second has not moved.  Those who are waiting to see how the first date goes in order to gauge whether the second will move won’t have much of a lead time.

This particularly applies, for example, to energy and commodity traders, who are tending to target the second date. I would say that they would be well advised to assume that the January date will stand unless they hear otherwise.