ESMA have just released a new Questions and Answers document on EMIR which can be found here.

There is not a huge amount in the document that will be of immediate concern to those in the energy and commodities trading sector, but the following items may be of interest:

• Some clarification on the inclusion of third country group positions in threshold calculations (OTC 3b4)
• A clarification on the intra-group exemption (OTC 6e)

The document still leaves many unanswered questions, particularly on the data definition side of things.