ISDA has published a paper highlighting concerns about the timetable for introducing the global margining framework for non-cleared derivatives. Each national regulator has agreed to adopt the same implementation schedule with a start date of 1 September 2016 for the largest banks and 1 March 2017 for all covered entities. However, it has been confirmed that the EU rules under EMIR would not be finalised in time for the September 2016 launch, meaning that the EU start date will be pushed to the middle of 2017. ISDA believes that the delay will have a far wider and more profound impact on cross-border trading, if other regulators retain the March 2017 deadline, and may create an uneven playing field, although the precise impact will depend on the status of every entity and the identity of their counterparties. In the light of the impact from March 2017 on the broader market, ISDA urges regulators to realign the global implementation deadline in the interests of ensuring that the market can continue to function effectively.