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After a long marathon from Lisbon to we finally hear the gun for the sprint to the finish. While 24 months, 8 quarters, 2 years is challenging, as an industry we can't protest lack of notification. While SEPA defines the end, the starting point is different for most and therein lies the root of the complexity. However, there are proven solutions available, so it is certainly possible. I think the passing of the regulation delivers a  necessary certainty to the industry. While the debate around interpretation will now commence, it would be sensible to respect the spirit of what the regulation sets out to achieve as the delegated powers to the Commission will enable quick 'text correction' to ensure those ends are achieved regardless. For the most part the debate can finish and the implementation phase commence in earnest. 

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Just to clarify. A Regulation is the legislative instrument used by the EU if something is not happening quickly enough or in the manner intended.

This proposal must now be approved by the European Parliment and the member states in the form of the council. The council can take several configurations and I suspect that in this case its the ECOFIN version(Finance Ministers). This can happen relatively quickly, particularly with the broad level of support that exists.

Officials expect mid 2011 for completion according to the FT article today. The revised Regulation is then published in the Official Journal and comes into force in relatively short order eg. Reg 924 was published on 09/10/09 and came into force on 01/11/09. We can expect something similar with this regulation.