Tomorrow (12th) is the first day on which daily valuation and collateral updates must be sent to Trade Repositories as part of the EMIR trade reporting rules.This requirement does not apply to non financial counterparties that are under the clearing threshold (NFC-).

Many in the energy and commodities markets are NFC-s so we have not seen a huge amount of work to meet this deadline. Never the less, there are some larger participants who are over the threshold(NFC+), and there are also some who have at least one subsidiary that is a “Financial Counterparty” (FC). Anyone in either of these categories will need to do at least some reporting.

There is a useful summary here on Derivsource giving some tips for compliance.