On November 19, 2015, ESMA announced that it was not going to further extend the exemption for non-financial counterparties from the obligation to provide collateralized bank guarantees for their energy derivatives cleared by EU CCPs. Therefore, from March 15, 2016, CCPs authorized under the European Market Infrastructure Regulation must fully collateralize commercial bank guarantees used to cover transactions in derivatives relating to electricity or natural gas produced. Non-financial counterparties have had a three-year grace period to ensure that they will be able to comply with the collateral obligations under EMIR which requires CCPs to only accept highly liquid collateral with minimal credit and market risk.

The ESMA announcement is available at: http://www.esma.europa.eu/news/ESMA-will-not-exempt-collateralisationbank-guarantees-energy-derivatives-under-EMIR?t=326&o=home