Although there has been push back on the final version of the rules (see here ) the start date of the MiFID II position limits draws closer. Unavista have announced this offering which helps market participants to report data to regulators under the position reporting aspects of the rules. The mechanism for such reporting is still not entirely final, especially given that the FCA consultation has stated that only investment firms need report. Since regulators will also need data from non investment firms it remains to be seen how this data will be collected.
While the rules do not explicitly require that market participants calculate the level of their own limits, most will wish to do so, in order to establish whether they are near a limit. This post by Gordon Allot of Broadpeak looks at some of the issues around the spot/other split.
Any market participant trading commodity derivatives will need to observe these rules, whether they pass the ancillary activity test or not. This is in contrast to the rest of MiFID, which is generally implemented by those who must set up regulated entities. It is worth understanding the order of magnitude of compliance in the coming weeks to determine when to start planning any necessary projects.