The FCA have updated their website and stated that they expect Portfolio Reconciliation, Portfolio Compression and Dispute Resolution to be up and working by 30th April this year. The updated statement is here with the relevant part at the bottom of the page.
The biggest impact in energy and commodities is likely to be on the reconciliation side. March 15th sees the popular date for annual reconciliation and this date will be a big test for many. The FCA expect any issues found then to be ironed out by end of April, and also for the dispute resolution procedures to be properly in place by then.
Compression also should not be forgotten for those who qualify. If it necessary to show a proper attempt and success in execution for any counterparty with more than 500 trades.