EMIR

Key implementation dates of the EMIR requirements are set out below.

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Timeline

  • 1 September 2020

    Initial Margin requirements fully phased in

  • 4 January 2020

    (1) Initial Margin requirements apply to transactions where one counterparty is a Third-Country entity and no equivalence decision for that Third Country has been adopted under Article 13(2) of EMIR; and (2) Variation Margin requirements apply for all non-centrally cleared derivatives on single stock equity options and index options

  • 2020
  • 1 September 2019

    Initial Margin requirements apply with IM Notional Amount Threshold of EUR0.75 trillion

  • 9 August 2019

    Clearing Obligation for Category 4 counterparties applies for OTC Interest Rate Swaps in additional currencies

  • 21 June 2019

    Clearing Obligation for Category 3 counterparties applies for: (1) OTC Interest Rate Swaps in G4 currencies; (2) certain OTC Credit Default Swaps based on an index; and (3) OTC Interest Rate Swaps in additional currencies

  • 9 May 2019

    Clearing Obligation for Category 4 counterparties applies for certain OTC Credit Default Swaps based on an index

  • 2019
  • 3 January 2018

    Variation Margin requirements apply to physically settled FX forward contracts [however subject to regulatory forbearance]

  • 1 September 2018

    Initial Margin requirements apply with IM Notional Amount Threshold of EUR1.5 trillion

  • 21 December 2018

    Clearing Obligation for Category 4 counterparties applies for OTC Interest Rate Swaps in G4 currencies

  • 2018
  • 1 September 2017

    Initial Margin requirements apply with IM Notional Amount Threshold of EUR2.25 trillion

  • 9 August 2017

    Clearing Obligation for Category 2 counterparties applies for (1) certain OTC Credit Default Swaps based on an index; and (2) OTC Interest Rate Swaps in additional currencies

  • 13 June 2017

    Publication of Commission legislative proposal for a Regulation amending Regulation (EU) 1095/2010 establishing ESMA and amending EMIR as regards the procedures and authorities involved for the authorisation of CCPs and requirements for the recognition of third-country CCPs

  • 2017
  • 4 May 2017

    Publication of Commission legislative proposal for a Regulation amending EMIR as regards the clearing obligation, the suspension of the clearing obligation, the reporting requirements, the risk mitigation techniques for OTC derivatives contracts not cleared by a central counterparty, the registration and supervision and trade repositories and the requirement for trade repositories

  • 1 March 2017

    Variation Margin requirements apply for all counterparties not caught on first VM phase-in date

  • 9 February 2017

    Clearing Obligation for Category 1 counterparties applies for (1) certain OTC Credit Default Swaps based on an index; and (2) OTC Interest Rate Swaps in additional currencies

  • 4 February 2017

    (1) Initial Margin requirements apply with IM Notional Amount Threshold of EUR3 trillion; and (2) Variation Margin requirements apply where both counterparties exceed an VM Notional Amount Threshold of EUR3 trillion (3) Initial Margin requirements start to apply to non-exempt group transactions where a Union counterparty enters into an OTC derivative contract with an entity of the same group domiciled in the Union or a Third Country

  • 4 January 2017

    RTS on risk mitigation techniques (i.e. margining) for OTC derivative contracts not cleared by a CCP in force

  • 2017
  • 21 December 2016

    Clearing Obligation for Category 2 counterparties applies for OTC Interest Rate Swaps in G4 currencies

  • 9 October 2016

    Frontloading for Category 1 and Category 2 counterparties applies for (1) certain OTC Credit Default Swaps based on an index; and (2) OTC Interest Rate Swaps in additional currencies

  • 2016
  • 9 August 2016

    RTS with regard to clearing for OTC Interest Rate Swaps in additional currencies in force

  • 21 June 2016

    Clearing Obligation for Category 1 counterparties applies for OTC Interest Rate Swaps in G4 currencies

  • 21 May 2016

    Frontloading for (1) Category 2 counterparties applies for OTC Interest Rate Swaps in G4 currencies

  • 9 May 2016

    RTS with regard to clearing for certain OTC Credit Default Swaps based on an index in force

  • 21 February 2016

    Frontloading for Category 1 counterparties applies for OTC Interest Rate Swaps in G4 currencies

  • 2016
  • 21 December 2015

    RTS with regard to clearing OTC Interest Rate Swaps in G4 currencies in force

  • 2015
  • 11 August 2014

    Market value reporting requirements for collateral in force

  • 12 February 2014

    Trade reporting for all asset classes in force

  • 2014
  • 15 September 2013

    (1) Portfolio reconciliation and dispute resolution; and (2) portfolio compression requirements in force

  • 15 March 2013

    (1) Timely confirmation requirements in force

  • 16 August 2012

    EMIR in force

  • 27 July 2012

    Text of the Regulation published in the Official Journal of the European Union

  • 2012–13
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The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to.
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