The rules around trade reporting under EMIR came into force over a year ago, as did most of its risk management measures. However, there is still a great deal of work to do under EMIR, which is outlined in this article on The OTC space web site, written by John Philpott. The post includes this clear diagram of what is to come.
As the article highlights, mandatory clearing has not started yet. This element of EMIR will have a great deal of impact of those caught under it. Many of those in commodities and energy are under the “clearing threshold” (i.e. an “NFC-“) and therefore will not be caught by mandatory clearing. However, it is likely that some of the market’s liquidity will shift towards cleared products. In addition, MiFID II may turn many in the sector into Financial Counterparties, at which point mandatory clearing will apply.
The trade reporting element of EMIR also still has a way to go. Firstly, level 2 validations will come into force at the end of October. Then the results of the recent consultation on new Regulatory Technical Standards on reporting will kick in, probably early next year. This means that the work on trade reporting, and the rest of EMIR, is far from done.