Research European Commodity Market Regulations - Part 2 | Page 6

European Energy Market Regulations – Survey Results

Action Plans
In order to see if general awareness of the regulations translated into planned actions, we also asked
if the respondents’ companies already had a fully resourced and budgeted program plan to comply
with the rules and whether that plan included both business and IT. In fact, only 45% of the
responding companies said that they had such a plan and only 35% have a plan that spreads across
business units and their IT departments. Thirty-two percent of the respondents stated that no such
plan existed, while 13% did not know. The remainder did not respond to the question. The survey
suggests that less than half of the companies in the survey are already planning the actions that are
required to comply with regulations.

EMIR Threshold Calculation
One key aspect of planning for EMIR is to know whether your company is under or over the ‘threshold’.
Figure 3: Are you able to calculate if you are you over or under the The survey suggests that just under
half of the responding companies are
EMIR threshold?
able to calculate their EMIR threshold
already on a daily basis, some 23%
7%
7%
require further clarification in order to
perform the calculation and just 7%
46%
17%
can’t perform the calculation.

23%

Yes

Maybe

Don't Know

No

No answer

Of the 14 respondents that can and
do calculate their EMIR threshold, six
have that process automated
already while eight companies
perform the calculation manually.
Furthermore, just over half of those
calculating the threshold are carrying
out a capital simulation exercise to see

the potential effects of clearing if you go over the threshold

Trade Confirmation Requirements
Just under 40% of the responding companies believe that they are already in compliance with the
new T+7/5 trade confirmations requirement. Around 20% said that they were not in compliance and
a further 26% did not know. However, only four respondents felt that they complied with the new
stricter confirmation requirements coming in while eleven said they were not in a position to comply
and a further eleven did not know. The answers to these two questions again indicate a significant
level of unpreparedness among the responding companies.

Portfolio Reconciliation
Another aspect of EMIR is the need to reconcile portfolios. We asked whether responding
companies intended to perform that trade reconciliation manually or by using a system. In fact,
around a quarter said they will perform portfolio reconciliation manually and 16% more will combine

© Commodity Technology Advisory LLC and ETR Advisory Ltd, 2013, All Rights Reserved.

December, 2013

6