Derivatives Update - Reporting Deadline For Back-Loaded Trades

European regulators have recently clarified that the start date for trade reporting of derivatives entered into on or after 16 August 2012, and which are still outstanding on 12 February 2014 ("Post-EMIR Outstanding Contracts") under the European Markets Infrastructure Regulation ("EMIR") is 12 February 2014.

The derivatives industry had commonly understood that such trades would benefit from a 90 day grace period, meaning the deadline for reporting would have been 5 May 2014.  This understanding had even been confirmed on the UK Financial Conduct Authority's website.  The Central Bank of Ireland has not yet been appointed as the EMIR competent authority in Ireland, and no official Irish regulatory guidance had been available on this point.