344. Successful implementation of any new reporting requirements can only take place if the industry is granted sufficient time to prepare for reporting under the new rules. Moreover, the industry can work efficiently on the implementation only once all the requirements, including any technical details thereof, are finalised. Too limited timelines as well as lack of detailed guidance and technical requirements make the implementation costly, inefficient and, often, close to impossible to be finalised in a correct and timely manner.

345. These concerns were voiced by many respondents to the EC's Fitness Check. As highlighted in the report on results of the Fitness Check, longer implementation timelines, starting from the finalisation of the detailed technical requirements, would decrease the reporting burden and enable companies to better comply with the new requirements.

346. Having in mind the above, ESMA proposes to defer the date of application of EMIR technical standards on reporting by 18 months. In ESMA's assessment this timeline should provide the industry with sufficient timeline for implementation once the relevant technical guidance (Guidelines on reporting and accompanying validation rules and ISO 20022 messages) is finalised.

Q101. Do you agree with the proposed timelines for implementation, i.e. 18 months from the entry into force of the technical standards?