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Unique Transaction Identifier for OTC Derivative Transactions

Unique Transaction Identifier for OTC Derivative Transactions
The RBI has mandated a Unique Transaction Identifier (UTI) for all OTC derivative trades from 1 January 2027, aligning India with global reporting standards. This will boost market transparency, aid systemic‑risk monitoring and is a key development for UPSC aspirants studying financial sector reforms.
RBI/2025-26/222 CO.FMRD.MIOD.No.8/11.01.057/2025-26 February 18, 2026 To All eligible market participants Madam / Sir, Unique Transaction Identifier for OTC Derivative Transactions The Unique Transaction Identifier (UTI) has been conceived as one of the key data elements identified globally for reporting over-the-counter (OTC) derivative transactions with a view to enable policy makers to obtain a comprehensive view of the OTC derivatives market. 2. At present, all transactions in OTC markets for Rupee interest rate derivatives, forward contracts in Government securities, foreign currency derivatives, foreign currency interest rate derivatives, and credit derivatives are reported to the Trade Repository managed by Clearing Corporation of India Limited (CCIL-TR). It has now been decided to mandate UTI for all such transactions. A framework for the implementation of UTI for OTC derivative transactions, is enclosed at . 3. The directions shall come into effect from January 01, 2027 and shall be applicable to OTC derivative transactions entered into on or after the date the directions come into effect. 4. These directions have been issued in exercise of the powers conferred under section 45W of the Reserve Bank of India Act, 1934 read with section 45U of the Act and of all the powers enabling it in this behalf. Yours faithfully, (Dimple Bhandia) Chief General Manager (Annex to circular CO.FMRD.MIOD.No.8/11.01.057/2025-26 dated February 18, 2026 on Unique Transaction Identifier for OTC Derivative Transactions) 1. The directions shall be applicable to all OTC derivative transactions undertaken in terms of the following directions (hereinafter “Governing Directions”): Foreign Exchange Management (Foreign Exchange Derivative Contracts) Regulations, 2000 ( ) and Master Direction – Risk Management and Inter-Bank Dealings ( ), as amended from time to time. Master Direction – Reserve Bank of India (Rupee Interest Rate Derivatives) Directions, 2025 ( ), as amended from time to time; Reserve Bank of India (Forward Contracts in Government Securities) Directions, 2025 ( ), as amended from time to time. Master Direction – Reserve Bank of India (Credit Derivatives) Directions, 2022 ( ), as amended from time to time. Any other Direction(s), as may be specified by the Reserve Bank. 2. Unique Transaction Identifier (UTI), a unique identifier assigned to an OTC derivative transaction, shall be generated / reported for all transactions in OTC derivatives market undertaken in terms of the Governing Directions. The directions shall be applicable to OTC derivative transactions entered into on or after the date the directions come into effect. 3. UTI shall be generated in accordance with the UTI Technical Guidance issued by the Committee on Payments and Market Infrastructures (CPMI) - International Organisation of Securities Commissions (IOSCO) in February 2017. It shall have a maximum of 52 characters comprising the Legal Entity Identifier (LEI) of the generating entity followed by a unique identifier and shall be unique to a derivative transaction throughout its lifecycle. 4. The UTI generating entity shall be determined as per the waterfall in with the responsibility of UTI generation assigned to the next entity in the waterfall in case the identified UTI generating entity is unable or unwilling to generate the UTI. In terms of the waterfall, if a transaction is reported to the Clearing Corporation of India Limited – Trade Repository (CCIL-TR) without the UTI, the CCIL-TR shall generate the UTI for the transaction. Table 1: Generation of UTI Transactions reportable only in India Transactions reportable in India and one or more foreign jurisdictions 1) The CCP, if the CCP is counterparty to the transaction. 1) The CCP, if the CCP is counterparty to the transaction. 2) The ETP, if the transaction is executed on an ETP. 2) Clearing Member, if a Clearing Member is counterparty to the transaction. 3) An entity as is mutually agreed between the counterparties. 3) ETP, if the transaction is executed on an ETP. 4) CCIL-TR. A. If a foreign jurisdiction has a sooner reporting timeline 4) An entity as per the requirements in the foreign jurisdiction. B. If the foreign jurisdiction does not have sooner reporting timeline 4) An entity as is mutually agreed between the counterparties. 5) CCIL-TR. 5. For transactions that are reportable in India and in a foreign jurisdiction and the foreign jurisdiction has a sooner reporting timeline, market participants may undertake reasonable efforts to ensure that the UTI is obtained and reported within the reporting deadline for the transaction. In case the market participant is unable to obtain the UTI within the reporting deadline, the market participant may obtain and submit the UTI to CCIL-TR at the earliest thereafter, but in any case, within five Mumbai business days from the date of the transaction. Any temporary UTI reported by the market participant or generated by the CCIL-TR when the transaction was initially reported, will then be treated as an interim UTI. 6. Amendments to a derivative contract, post reporting to the CCIL-TR, shall not necessitate the generation of a new UTI. However, a lifecycle event such as novation that results in the creation of a new reportable derivative contract, as per extant reporting guidelines, shall necessitate the generation of a new UTI. 7. CCIL shall issue the operating guidelines and reporting formats for reporting of UTI. 8. Market participants shall ensure that necessary arrangements are put in place for ensuring compliance with these directions.
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Key Insight

RBI mandates Unique Transaction IDs for OTC derivatives to boost market transparency from 2027

Key Facts

  1. RBI circular (CO.FMRD.MIOD.No.8/11.01.057/2025-26) dated 18 Feb 2026 mandates a Unique Transaction Identifier (UTI) for all OTC derivative transactions.
  2. The UTI requirement will be effective from 1 Jan 2027 for transactions entered into on or after that date.
  3. UTI must be generated as per CPMI‑IOSCO (Feb 2017) technical guidance: max 52 characters, starting with the LEI of the generating entity.
  4. Applicable OTC derivatives include rupee interest‑rate derivatives, forward contracts in government securities, foreign‑currency derivatives and credit derivatives, reported to CCIL‑TR.
  5. UTI generation follows a waterfall: CCP (if counter‑party) → Exchange‑Traded Platform → Clearing Member → mutually agreed entity → CCIL‑TR (if no UTI).
  6. If a foreign jurisdiction has an earlier reporting deadline, participants must obtain UTI within that deadline; otherwise it must be submitted to CCIL‑TR within five Mumbai business days.
  7. Amendments to a reported contract do not require a new UTI, but a lifecycle event like novation does.

Background

The move aligns India with global post‑trade transparency standards (CPMI‑IOSCO) and strengthens RBI's oversight of the rapidly growing OTC derivatives market, thereby curbing systemic risk and enhancing data‑driven policy making.

UPSC Syllabus

  • GS2 — Government policies and interventions for development

Mains Angle

GS III – Financial Sector Reforms: Discuss how the introduction of a Unique Transaction Identifier for OTC derivatives enhances market transparency, risk monitoring and regulatory oversight in India.

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RBI/2025-26/222 CO.FMRD.MIOD.No.8/11.01.057/2025-26 February 18, 2026 To All eligible market participants Madam / Sir, Unique Transaction Identifier for OTC Derivative Transactions The Unique Transaction Identifier (UTI) has been conceived as one of the key data elements identified globally for reporting over-the-counter (OTC) derivative transactions with a view to enable policy makers to obtain a comprehensive view of the OTC derivatives market. 2. At present, all transactions in OTC markets for Rupee interest rate derivatives, forward contracts in Government securities, foreign currency derivatives, foreign currency interest rate derivatives, and credit derivatives are reported to the Trade Repository managed by Clearing Corporation of India Limited (CCIL-TR). It has now been decided to mandate UTI for all such transactions. A framework for the implementation of UTI for OTC derivative transactions, is enclosed at . 3. The directions shall come into effect from January 01, 2027 and shall be applicable to OTC derivative transactions entered into on or after the date the directions come into effect. 4. These directions have been issued in exercise of the powers conferred under section 45W of the Reserve Bank of India Act, 1934 read with section 45U of the Act and of all the powers enabling it in this behalf. Yours faithfully, (Dimple Bhandia) Chief General Manager (Annex to circular CO.FMRD.MIOD.No.8/11.01.057/2025-26 dated February 18, 2026 on Unique Transaction Identifier for OTC Derivative Transactions) 1. The directions shall be applicable to all OTC derivative transactions undertaken in terms of the following directions (hereinafter “Governing Directions”): Foreign Exchange Management (Foreign Exchange Derivative Contracts) Regulations, 2000 ( ) and Master Direction – Risk Management and Inter-Bank Dealings ( ), as amended from time to time. Master Direction – Reserve Bank of India (Rupee Interest Rate Derivatives) Directions, 2025 ( ), as amended from time to time; Reserve Bank of India (Forward Contracts in Government Securities) Directions, 2025 ( ), as amended from time to time. Master Direction – Reserve Bank of India (Credit Derivatives) Directions, 2022 ( ), as amended from time to time. Any other Direction(s), as may be specified by the Reserve Bank. 2. Unique Transaction Identifier (UTI), a unique identifier assigned to an OTC derivative transaction, shall be generated / reported for all transactions in OTC derivatives market undertaken in terms of the Governing Directions. The directions shall be applicable to OTC derivative transactions entered into on or after the date the directions come into effect. 3. UTI shall be generated in accordance with the UTI Technical Guidance issued by the Committee on Payments and Market Infrastructures (CPMI) - International Organisation of Securities Commissions (IOSCO) in February 2017. It shall have a maximum of 52 characters comprising the Legal Entity Identifier (LEI) of the generating entity followed by a unique identifier and shall be unique to a derivative transaction throughout its lifecycle. 4. The UTI generating entity shall be determined as per the waterfall in with the responsibility of UTI generation assigned to the next entity in the waterfall in case the identified UTI generating entity is unable or unwilling to generate the UTI. In terms of the waterfall, if a transaction is reported to the Clearing Corporation of India Limited – Trade Repository (CCIL-TR) without the UTI, the CCIL-TR shall generate the UTI for the transaction. Table 1: Generation of UTI Transactions reportable only in India Transactions reportable in India and one or more foreign jurisdictions 1) The CCP, if the CCP is counterparty to the transaction. 1) The CCP, if the CCP is counterparty to the transaction. 2) The ETP, if the transaction is executed on an ETP. 2) Clearing Member, if a Clearing Member is counterparty to the transaction. 3) An entity as is mutually agreed between the counterparties. 3) ETP, if the transaction is executed on an ETP. 4) CCIL-TR. A. If a foreign jurisdiction has a sooner reporting timeline 4) An entity as per the requirements in the foreign jurisdiction. B. If the foreign jurisdiction does not have sooner reporting timeline 4) An entity as is mutually agreed between the counterparties. 5) CCIL-TR. 5. For transactions that are reportable in India and in a foreign jurisdiction and the foreign jurisdiction has a sooner reporting timeline, market participants may undertake reasonable efforts to ensure that the UTI is obtained and reported within the reporting deadline for the transaction. In case the market participant is unable to obtain the UTI within the reporting deadline, the market participant may obtain and submit the UTI to CCIL-TR at the earliest thereafter, but in any case, within five Mumbai business days from the date of the transaction. Any temporary UTI reported by the market participant or generated by the CCIL-TR when the transaction was initially reported, will then be treated as an interim UTI. 6. Amendments to a derivative contract, post reporting to the CCIL-TR, shall not necessitate the generation of a new UTI. However, a lifecycle event such as novation that results in the creation of a new reportable derivative contract, as per extant reporting guidelines, shall necessitate the generation of a new UTI. 7. CCIL shall issue the operating guidelines and reporting formats for reporting of UTI. 8. Market participants shall ensure that necessary arrangements are put in place for ensuring compliance with these directions.
Read Original on rbi

RBI mandates Unique Transaction IDs for OTC derivatives to boost market transparency from 2027

Key Facts

  1. RBI circular (CO.FMRD.MIOD.No.8/11.01.057/2025-26) dated 18 Feb 2026 mandates a Unique Transaction Identifier (UTI) for all OTC derivative transactions.
  2. The UTI requirement will be effective from 1 Jan 2027 for transactions entered into on or after that date.
  3. UTI must be generated as per CPMI‑IOSCO (Feb 2017) technical guidance: max 52 characters, starting with the LEI of the generating entity.
  4. Applicable OTC derivatives include rupee interest‑rate derivatives, forward contracts in government securities, foreign‑currency derivatives and credit derivatives, reported to CCIL‑TR.
  5. UTI generation follows a waterfall: CCP (if counter‑party) → Exchange‑Traded Platform → Clearing Member → mutually agreed entity → CCIL‑TR (if no UTI).
  6. If a foreign jurisdiction has an earlier reporting deadline, participants must obtain UTI within that deadline; otherwise it must be submitted to CCIL‑TR within five Mumbai business days.
  7. Amendments to a reported contract do not require a new UTI, but a lifecycle event like novation does.

Background & Context

The move aligns India with global post‑trade transparency standards (CPMI‑IOSCO) and strengthens RBI's oversight of the rapidly growing OTC derivatives market, thereby curbing systemic risk and enhancing data‑driven policy making.

UPSC Syllabus Connections

GS2•Government policies and interventions for development

Mains Answer Angle

GS III – Financial Sector Reforms: Discuss how the introduction of a Unique Transaction Identifier for OTC derivatives enhances market transparency, risk monitoring and regulatory oversight in India.

Analysis

Related PYQs

No related PYQs linked to this article yet.

Practice Questions

GS3
Easy
Prelims MCQ

Regulatory reforms in financial markets

1 marks
3 keywords
GS3
Medium
Mains Short Answer

Derivatives market transparency

5 marks
4 keywords
GS3
Hard
Mains Essay

Financial market reforms and global convergence

20 marks
6 keywords
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