Mandatory compliance for Category 1 counterparties – typically global banks and brokers – already had taken place with the clearing obligation as from June 2016. Other clearing obligation deadlines will hit the other categories of firms until August 2019 (Category 4).
For the non-cleared OTC Derivatives, initial margin and variable margin requirements applied in Europe for the high-volume users as of 4 February 2017 – following the US, Canada and Japan who had to comply as of 1 September 2016.
In addition, on 1 March 2017, variable margin requirements started to apply for all counterparties not impacted by the initial February date. However, the rules introduced a staggered schedule for the implementation of initial margin requirements which means that some firms, mainly buy-side, need only to comply by 1 September 2020.