With the EMIR trade reporting deadline of 12th February almost upon us, I find it slightly unsettling that I'm still hearing rumblings of "will they extend the deadline...?" from all sorts of market participants. It's clear that the ESMA hasn't given any signs of extending the reporting deadlines (even if they have softened some of the edges).

A recent informal poll during a webinar from one of the authorised Trade Repositories (TRs) revealed that 91.6% of the participants felt they were fully prepared, but perhaps what was more interesting was that not all brokerage businesses (investment banks and broker firms) have announced plans to offer delegated reporting to their buy-side clients.

One key area to observe after reporting has started will be the behaviour of buy-side firms. Most have opted to use the delegated reporting offerings of their broker(s) but of course delegated reporting doesn't mean delegated responsibility.

As Richard Wilkinson, senior associate at Contango recently noted at an FOA event in London, some firms on the buy-side have a "blinkered view" that once they delegate their trade reporting, the responsibility goes away. "The reality is, brokers say they are not responsible for anything once the trade has been reported," he warned. "So people are in denial about what delegating means." Richard added that firms needed to act tactically now to hit the reporting deadlines – but be mindful of their longer term strategy.

Of course, a significant complication in all of this is that there are always multiple sides and legs to most trades and when multiple TRs are involved, as there surely will be in many cases, the complexities of issues such as reconciliation are probably being under estimated by many buy-side firms.

Is that the light at the end of the tunnel...or an express train heading towards us?!