Following confirmation by ESMA of the fact that, on 18 March 2014, Nasdaq OMX was authorised as a CCP under EMIR and of the classes of OTC derivatives that it has been authorised to clear, you might be wondering what happens next. Well, Simmons & Simmons have helped out again by providing another useful article. In summary, the authorisation of Nasdaq OMX kick starts the EMIR ‘frontloading’ requirement for those classes of OTC derivatives for which Nasdaq OMX has been authorised. In other words, if any class of OTC derivatives which Nasdaq OMX is authorised to clear subsequently becomes subject to a mandatory clearing requirement, all trades entered into after the declaration of mandatory clearing as well as all trades entered into on or after the date of authorisation (i.e. 18 March 2014) will be required to be cleared. The next significant date in this process is 18 September 2014 – the deadline for ESMA to submit a regulatory technical standard for approval by the EU Commission proposing the sub-set of trades for which Nasdaq OMX has been authorised which should be subject to mandatory clearing.