The Reserve Bank of India has issued directions requiring all eligible market participants to generate and report a Unique Transaction Identifier (UTI) for over-the-counter (OTC) derivative transactions reported to the Clearing Corporation of India Limited’s trade repository (CCIL-TR). The requirement applies from 1 January 2027 and covers OTC derivative transactions entered into on or after that date. The mandate applies to OTC derivative transactions undertaken under specified RBI and FEMA frameworks, including rupee interest rate derivatives, forward contracts in government securities, foreign exchange and foreign currency derivative directions, foreign currency interest rate derivatives, and credit derivatives, as well as any other directions the RBI may specify. UTIs must be generated in line with the CPMI-IOSCO UTI Technical Guidance (February 2017), with a maximum of 52 characters comprising the generating entity’s Legal Entity Identifier followed by a unique identifier, and must remain unique to a transaction across its lifecycle. A “waterfall” determines the UTI generating entity (including CCPs, electronic trading platforms, mutually agreed counterparties, or CCIL-TR), with CCIL-TR required to generate a UTI where a report is submitted without one. For transactions reportable in India and a foreign jurisdiction with an earlier reporting deadline, participants should make reasonable efforts to obtain and report the UTI within the applicable deadline; where that is not possible, the UTI must be submitted as soon as practicable and in any case within five Mumbai business days of the transaction date, with any temporary identifier treated as an interim UTI. Contract amendments after reporting do not require a new UTI, but lifecycle events such as novation that create a new reportable derivative contract do. CCIL will issue operating guidelines and reporting formats, and market participants are expected to put the necessary arrangements in place to comply.
Reserve Bank of India 2026-02-18
Reserve Bank of India mandates Unique Transaction Identifier reporting for OTC derivative transactions from 1 January 2027
The Reserve Bank of India mandates eligible market participants to report a Unique Transaction Identifier (UTI) for over-the-counter derivative transactions to the Clearing Corporation of India Limited’s trade repository, effective 1 January 2027. This requirement covers derivatives under RBI and FEMA frameworks, with UTIs generated per CPMI-IOSCO guidance. CCIL will provide guidelines, and participants must comply with reporting deadlines, including interim measures for cross-jurisdictional transactions.