May 25, 2013

EMIR timeline moved by 5 months | Earliest Start for Clearing now May 2014

On the ESMA website a new timeline popped into view a few days ago (Source:, which I have added to the log of these timelines on my Official EMIR Timeline page.

There's two interlocking dates on their timeline, the earliest date on which a CCP can achieve authorisation (moved from April to September) and the earliest date on which ESMA publish their Recommended Technical Standards which specify which products are to be cleared, moved from October this year to March 2014.

In the previous dependency chain a CCP could be authorised as soon as 15th April this year, (step C) on the previous chart, with the RTS coming in October this year. The new chain puts authorisation no earlier than September, and the RTS no earlier than March next year, but possibly as late as September 2014.

Additionally, the ESMA page says this:

As for the clearing obligation, following the submission by ESMA of the draft regulatory technical standards, as indicated in the graph below, these draft RTS will need to be endorsed by the European Commission (1-3 months) and non-objected by the European Parliament and the Council (1-3 months). The actual date of application of the clearing obligation will depend on the date of entry into force of these RTS and the expected phase-in period per type of counterparty, to be defined in the RTS.

So this means another bar (not shown on the chart) of between 2 to 6 months for the Commission and Parliament to endorse the RTS before everyone can then start their EMIR engines.

Implied clearing start dates now

  • Earliest date would be publication of RTS, plus the 2 months review = 15 March 2014 + 2 months = 15th May 2014 (previously Oct + 2 = Dec 2013)
  • Latest date would be publication of RTS, plus 6 months review = 15th September 2014 + 6 months = 15th March 2015 (No change)

Timeline as of May 22nd


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