On 31 October 2018, the European Securities and Markets Authority (ESMA) issued a statement  relating to the challenges that certain groups, as well as certain non-financial counterparties above the clearing threshold (NFC+), would face on 21 December 2018 to start CCP clearing some of their OTC derivative contracts and trading them on trading venues.

Under Regulation (EU) No 648/2012 (EMIR), both:

  1. The current derogation from the clearing obligation for certain intragroup transactions concluded with a third country group entity; and
  2. The phase-in for counterparties in Category 4, broadly speaking NFCs+,

expire on 21 December 2018, for the interest rate derivative classes denominated in the G4 currencies subject to the clearing obligation.