HM Treasury (UK government) have opened a consultation on the transposition of MiFID II into UK law. MiFID must be transposed into law in each member state by mid 2016. The various consultation documents can be found here.
Page 21 of the main document discusses position limits and reporting, including the fact that such legislation will be created as “stand alone”, since it applies to those with or without MiFID licences. There are also other interesting discussions, for example the about the applicability of the limits to both UK positions, and those linked to them. Page 4 of Annex A highlights the actual transposition.
There is also a MiFID Impact Assessment. Paragraph 10 on page 4 talks about the reduction in exemptions. This continues on page paragraphs 115 and 116, where it is estimated that the increase in the number of MiFID firms due to the loss of exemptions relative to the current number will be less than 2%. This would appear to downplay the potential impact as seen by many members of the commodity trading industry.
Paragraphs 66 to 68 on page 10 talk about position limits. The document estimates that there are 1800 commodity derivative contracts on UK venues.