For consistency with the clearing threshold calculations of Article 4a and 10 of EMIR, the “notional clearing volume outstanding” as referred to in Article 7a, paragraph 4 and 8 of EMIR, should be calculated as the “aggregate month-end average position for the previous 12 months” of cleared trades. 

Every month counterparties should compare their aggregate month-end average position for the previous 12 months, against the EUR 6bn and 100bn thresholds of in Article 7a, paragraph 4 and 8, to continuously monitor their obligations, in line with ESMA Q&A 2776 and 2777.

The calculation of the “aggregate month-end average position” should take into account the specificities of ESMA OTC Q&A 3 (b), (c) and (f).