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Unique Transaction Identifier (UTI) for OTC Derivative Transactions

Reserve Bank of India (RBI) has issued directions on Unique Transaction Identifier (UTI) for over-the-counter (OTC) derivative transactions.

What are the existing norms for reporting of OTC derivative transactions?

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). 

What are the directions on Unique Transaction Identifier (UTI) for OTC derivative transactions?

  • Unique Transaction Identifier (UTI), a unique identifier assigned to an OTC derivative transaction, shall be generated / reported for all transactions in OTC derivatives market. 
  • The directions shall be applicable to OTC derivative transactions entered into on or after January 01, 2027.
  • 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. 
  • UTI 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.
  • The UTI generating entity shall be determined as per the waterfall in table below 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 CCIL-TR without the UTI, the CCIL-TR shall generate the UTI for the transaction.

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.

  • 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 5 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.
  • 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.
  • CCIL shall issue the operating guidelines and reporting formats for reporting of UTI.


References

Reserve Bank of India. (2026, February 18). 'RBI releases Circular on Unique Transaction Identifier for OTC Derivative Transactions'. Retrieved from https://www.rbi.org.in/Scripts/BS_PressReleaseDisplay.aspx?prid=62254

Reserve Bank of India. (2026, February 18). 'Unique Transaction Identifier for OTC Derivative Transactions'. Retrieved from https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13307&Mode=0


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