The timeline for reporting under EMIR has slipped giving everyone a bit more breathing space.
Until the slippage the probable start date for reporting to a Trade Repository (TR) in respect of interest rate and credit derivatives (OTC and exchange traded) was this September, and 1 January 2014 for reporting of all other asset classes of derivatives.
As there are not yet any TRs to report to (ESMA’s best guess is that the first approval of a TR is “not likely to take place before 24 September 2013”), the reporting start date for interest rate and credit derivatives is now 1 January 2014. Note that the start date for all other asset classes remains 1 January 2014.
Although EMIR is now in force, unlike, say, the AIFMD “start date” of 22 July 2013, the above dates are not fixed in stone but are best estimates (the EMIR Regulation was drafted so that reporting is supposed to start 90 calendar days after a TR for that asset class has been approved/registered).
A brief summary of EMIR’s requirements and what firms should be doing in anticipation can be found in Regulatory Roundup 46.