EMIR Timeline

EU EMIR 3 amendments to take effect (specific dates not yet known)

UK Refit reporting requirements take effect

EU Refit reporting requirements take effect

Initial Margin requirements fully phased in

(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

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

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

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

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

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

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

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

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

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

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

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

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

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

(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

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

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

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

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

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

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

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

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

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

Market value reporting requirements for collateral in force

Trade reporting for all asset classes in force

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

(1) Timely confirmation requirements in force

EMIR in force

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