ESMA and the national regulators in EU member states have updated their work plan for the opinions MiFID 2 requires on pre-trade transparency waivers and position limits. Around 700 of the former and 110 of the latter opinions need to be issued, so there is a plan to ensure they can be implemented pending the opinions actually being issued. ESMA will prioritise equity waivers and will aim to finalise those by the end of 2017. It will then start work on the non-equity waivers but does not expect to have got through many by 3 January 2018. Member States will make their own assessments and grant temporary, provisional waivers.
On position limits, ESMA has run out of time, so it and the NCAs will publish guidance on limits which will enter into force, pending the publication of opinions as a result of which the NCAs may modify the limits.