The Reserve Bank of India (RBI) has issued a Master Direction consolidating its requirements on the use of global unique identifiers in RBI-regulated financial markets, covering both the Legal Entity Identifier (LEI) and the Unique Transaction Identifier (UTI). The LEI provisions take effect immediately, while the UTI framework will apply from 1 January 2027. The LEI requirement applies to all over-the-counter (OTC) transactions undertaken by entities other than individuals in the markets for government securities, money market instruments, foreign exchange instruments and derivatives. For users or clients undertaking non-derivative foreign exchange transactions, LEI is required only where the transaction amount is at least USD 1 million (or equivalent). Eligible resident and non-resident participants must obtain an LEI from a Global Legal Entity Identifier Foundation (GLEIF)-accredited Local Operating Unit, and entities executing, reporting or performing depository functions must capture counterparties’ LEIs in their systems. Entities without a current LEI are not eligible to transact in RBI-regulated financial markets. The UTI framework will apply to all OTC derivative transactions entered into on or after 1 January 2027 under specified RBI directions and regulations, including foreign exchange derivatives, rupee interest rate derivatives, forward contracts in government securities and credit derivatives. UTIs must follow the CPMI-IOSCO February 2017 technical guidance, with generation responsibility determined by a waterfall that can allocate responsibility to the central counterparty, electronic trading platform, an agreed entity between counterparties, or the Clearing Corporation of India Limited Trade Repository (CCIL-TR), which will generate the UTI if a trade is reported without one. For transactions reportable in India and abroad where the foreign jurisdiction has an earlier reporting deadline, UTIs may be submitted after the reporting deadline but within five Mumbai business days, with any temporary identifier treated as interim. CCIL will issue operating guidelines and reporting formats, and the Master Direction supersedes five earlier RBI circulars on LEI and UTI implementation.
Reserve Bank of India 2026-03-27
Reserve Bank of India issues master direction consolidating LEI requirements and starting UTI generation for OTC derivatives from January 2027
The Reserve Bank of India (RBI) issued a Master Direction consolidating requirements for global unique identifiers in RBI-regulated financial markets, covering the Legal Entity Identifier (LEI) and Unique Transaction Identifier (UTI). LEI provisions are effective immediately for OTC transactions in various markets, with a USD 1 million threshold for non-derivative foreign exchange transactions. The UTI framework, effective from 1 January 2027, applies to OTC derivatives, with guidelines for UTI generation and reporting.