• Margin on uncleared derivatives: EU regulators are expected to finalise in January 2016 detailed rules setting out the application of initial and variation margin requirements, that will be phased in from September 2016. Similar collateral requirements in the US and certain other countries, based on the revised framework for margin requirements for non-centrally cleared derivatives adopted by the Basel Committee on Banking Supervision (BCBS) and the International Organization of Securities Commissions (IOSCO) in March 2015, are also expected to be phased in from September 2016. See below under “USA” regarding implementation of this framework in the US.
  • Mandatory clearing: Following publication in the EU Official Journal on 1 December 2015 of the relevant technical standards, the EMIR clearing obligation will take effect in relation to certain OTC interest rate derivatives from 21 June 2016. The clearing obligation will be phased in so most non-financial counterparties will not need to clear these derivatives through qualifying CCPs until 21 December 2018.
  • Margin period of risk (MPOR): On 14 December 2015, ESMA published a consultation paper reviewing Article 26 of Commission Delegated Regulation 153/2013, concerning time horizons for the liquidation period or “margin period of risk”, with respect to client clearing accounts. This consultation closes on 1 February 2016.
  • Trade repository data: ESMA published on 11 December 2015 a consultation paper on access, aggregation and comparison of trade repository data. This consultation will close on 1 February 2016.
  • Indirect clearing – responses to ESMA consultation: On 21 December 2015, ESMA published the responses received to its November 2015 consultation on indirect clearing under EMIR and MiFIR, which closed on 17 December.