The Financial Conduct Authority last week published this implementation review of how energy and oil companies are doing with their EMIR Implementations. Much of the focus is on threshold calculation although other parts of EMIR such as Trade Reporting and confirms are also included.

Items of note that are mentioned include:

• A proportion of trades have moved to exchanges in order to avoid being included in the threshold.
• A proportion of physical trades has been re directed away from MTFs in order to avoid being included in the threshold.
• Back-loading has been difficult.
• There are many mismatches of trade reports.

There are some interesting things that are not being said such as:

• The breadth of calculation methods for notional for threshold calculation, which in energy and commodities can vary.
• The fact that the lack of matching reports is often due to lack of clarity on the correct values to put in fields in the first place.

The latter item continues to be a significant issue for much of the market.