With the MiFID II/MiFIR deadline now less than 14 months away, there is a great deal of work to do. This applies to all in the commodities industry, in particular those who lose their exemptions. Those in the financial industry will often have even more to do. As a result, many wish for a delay to the start of the rules.
This article on the Money Marketing web site argues for such a delay, and indicates that some in the European Parliament would consider pushing the date out. There have also been comments from MEPs, including Kay Swinburne, that some aspects of the Regulatory Technical Standard (RTS) could be rejected, as reported here on The Trade News web site. This would give even less time for compliance if the date is not moved. However the article also notes comments that even with disagreement, it is unlikely that the rules as a whole will be delayed. The best that can be hoped for is for some items to be “phased in”. Comments by regulators at several conferences indicate that since there are no transitional arrangements in the Level 1 text, unless it is changed by the European Parliament, even a phase in may not be offered.
Those who have not yet started preparing for MiFID II, whether by carrying out the exemption calculation or commencing work on MiFID authorisation, are thus advised to start without delay. This is made harder because the “denominators” of the threshold calculations are not available. However there is no reason not to carry out the rest of the calculation, which will give a good idea of exemption status.