ESMA have issued a discussion paper on how they intend to implement clearing.
Many of those in the energy sector will be trying to avoid much of this by staying under the threshold. However many are also modeling the capital impact should they go over. This is a wise move. It is unlikely that the regulator will be happy with most of the energy industry avoiding clearing, and if too many are under the threshold it is likely that they will re legislate to move more people over.
It is recommended that capital simulation be kicked off in the very near future.