This article in Eurotreasurer repeats what many have said in the last few weeks, including the FCA: That regulators are likely to be lenient for those who do not make the EMIR deadline, so long as they have not ignored EMIR, and keep trying to go live, within a reasonable time frame.

Bear in mind however, that an “indication” is not a guarantee of a non fine. It is wise to assume that non compliance will result in trouble, and not to slow down until you are live. Also remember that each country has a different regulator, who each have different attitudes.