The start of a new year gives us a chance to consider what lies ahead. 2024 is the 11th year of this blog, and once again a busy year awaits us.
The initial change that will be high on many priority lists will be EMIR REFIT (see here), which starts in the EU on 29th April and in the UK on 30th September. This significant change in EMIR reporting will require changes for most engaging in derivatives transactions. While many in energy and commodities delegate a significant proportion of such activity, most will have some residual self-reporting and will also need to address reconciliation issues. Most other jurisdictions will also have a similar change, for example in Singapore (see here).
We await the final text of REMIT II which is imminently expected(see here). This will give rise to changes for many in terms of monitoring, algorithmic trading controls and more. Those outside the EU will also need to comply with new rules around “representation”. As announced at the recent ACER REMIT forum, changes to REMIT reporting will continue to be discussed and implemented. Anti abuse activity by regulators will also likely continue. In Switzerland, we will learn more about “BATE”, the upcoming “Swiss REMIT” (see here).
The end of this month also sees the first deadline for CBAM reporting as part of the pilot before the full rules start in 2026. (see here). The details of such reporting, especially in relation to electricity, can be challenging. We can expect more clarifications over the coming months.
In the UK, the FCA’s consultation on reforming the commodity derivatives framework (see here) and the TCLC (see here) will keep many busy, in addition to other work, such as on the UK version of CBAM (see here).
And of course every market participant will have to keep on top of day-to-day issues, market design changes and interventions (for example the extension of the MCM, here), and the need to constantly improve policies, processes, procedures, conduct and governance.
This blog will continue to cover the above and more, free of charge, as far as possible. Those wanting a more detailed and customised service are encouraged to subscribe to ETR Advisory’s Regulatory Support Service (see here). This service will be the subject of an exciting partnership announcement over the coming days. The run up to e-World in February (see here) will also see other announcements.
We thank all our readers for your attention so far. We will continue to try to keep the market informed with useful information in 2024.