ESMA have issued a new questions and answers document on EMIR, which can be found here. It contains one new question, on page 36 which relates to the forthcoming clearing obligation. The obligation starts in phases, with the effective date depending on which of four “categories” the entity is in, with Category 1 starting first (on June 21st) and Category 4 (Non Financial Counterparties over the clearing threshold” starting later.
The answer discusses by when entities should determine which category they are in, and how and by when they should communicate the outcome to their counterpatries