The European Commission is considering a one-year delay for the implementation date of MiFID II. The new date is likely to be January 2018. Indeed, the entire MiFID II/MiFIR framework was supposed to be applicable as of 3 January 2017. In the meantime, on 21st of December, the European Securities and Markets Authority (ESMA) published the responses received to the consultation on indirect clearing under EMIR and MiFIR. On 23rd of December 2015, ESMA published a consultation paper on guidelines regarding transaction reporting; reference data; order record keeping and clock synchronisation (open for comment until 23rd March 2016.)
As regards EMIR, mandatory central clearing of Interest Rate Swaps (IRS) for Category 1 counterparties will begin on 21st June 2016, with other categories of counterparty phased-in at later dates. There are several similarities between EMIR and MiFID reporting requirements: both affect buy-side and most asset classes (Commodity derivatives, Exchange Traded Derivatives - ETD and OTCs where the underlying assets are traded at a trading venue). The transactions have to be reported no later than the following working day (T+1) and the information required is very detailed, including the legal entity identifiers (LEI) for the purpose of client identification in the transaction reports.
CACEIS has recognised experience in producing regulatory reports for its clients, having offered a MiFID reporting service since 2009, and an EMIR reporting service since the beginning of 2014. The group’s product team is constantly developping innovative solutions that will enable clients to comply with compliance with new MiFID II/MiFIR and EMIR obligations as they come into force.