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Frontloading is not applicable for Categories 3 and 4.Regarding third (non-EEA) countries (3C), there are three main areas of concern that were identified by ESMA: recognition of third country (non-EEA) CCPs, recognition of third country (non-EU) trade repositories (TRs), and identification of potentially duplicative or conflicting requirements regarding reporting and clearing obligations and risk mitigating techniques under EMIR.
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ESMA asked the European Commission to delay this date.
Generally, no mandatory clearing for corporates unless they exceed the clearing thresholds (i.e.
The timing of entering into force of the clearing requirements for the different categories is as follows: Category 1: 21 June 2016 with a frontloading application as of 21 February 2016 (4-month frontloading).
counterparties with average gross notional outstanding over a 3-month period exceeding EUR 8bn un-cleared OTC derivative contracts).
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Just making calls to “feel out the situation” wastes everyone’s time and could hurt your efforts later.