Long-Stop Date - Emissions Annex Provision

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EU Emissions Allowance Transaction Annex to the 2005 ISDA Commodity Definitions

A Jolly Contrarian owner’s manual™

Long-Stop Date in a Nutshell

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Long-Stop Date in all its glory

Long-Stop Date: Means, in respect of a Suspension Event that occurs with respect to a delivery or acceptance obligation that would otherwise be required to be performed within the period:
(1) from (and including) 1 May 2021 to (and including) 31 December 2022, 1 June 2024;
(2) from (and including) 1 January 2023 to (and including) 31 December 2024, 1 June 2026;
(3) from (and including) 1 January 2025 to (and including) 31 December 2026, 1 June 2028 ;
(4) from (and including) 1 January 2027 to (and including) 31 December 2028, it shall be 1 June 2030; and
(5) from (and including) 1 January 2029 to (and including) the twenty-fifth (25th) calendar day of the month in which the End of Phase Reconciliation Deadline is scheduled to occur, the twenty-fifth (25th) calendar day of the month in which the End of Phase Reconciliation Deadline is scheduled to occur.


See our natty emissions comparison table between the IETA, EFET and ISDA versions of emissions trading docs

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Pro tip: for tons of information about EU ETS and EU financial services regulation see Michał Głowacki’s magnificent emissions-euets.com website.

Emissions trading documentation
ISDA: EU AnatomyEU Wikitext EU Nutshell (premium) • UK AnatomyUK Wikitext (to be merged into EU Anatomy)
IETA: IETA Master AgreementIETA WikitextIETA Nutshell (premium)
EFET: EFET Allowances AppendixEFET Allowances WikitextEFET Nutshell (premium)



Relevant for Suspension Events, and to be compared with Settlement Disruption Events



Just what ISDA’s crack drafting squad™ thought it was up to here is anyone’s guess, but it sure as hell is arbitrary. Were they smoking something? It is really hard to account for this drafting any other way.

IN ANY CASE — if you have suffered a Suspension Event (meaning your Registry is unavoidably closed so you can’t settle transfers of Allowances) this Heath Robinson scheme divides the Fourth Compliance Period into arbitrary two year periods, and sets the Long-Stop date half a year after the end of these.

Which results in a weird outcome we are almost certain people will overwrite: If your delivery obligation fell on the 29th December 2023, your Long-Stop Date would be 1 June 2024, just six months away. If it fell just five days later on the 3rd of January 2024, your Long-Stop Date is 1 June 2027, two and a half years away.

You sense the ’squad was getting tired here, fed up with the abject lack of feedback from the working group, thought, “look, no-one will read this shit anyway, and if they do they’ll overwrite it” (er ... correct) so let’s just put in something random and move on.

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  • The JC’s famous Nutshell summary of this clause
Template:M premium EUA Annex Long-Stop Date

See also