**Executive Summary**
The Reserve Bank of India (RBI) issued a directive mandating the use of a Unique Transaction Identifier (UTI) for all Over-the-Counter (OTC) derivative transactions. This requirement aims to improve the comprehensive view of the OTC derivatives market for policymakers. The mandate comes into effect on January 01, 2027 and will apply to all OTC derivative transactions entered into on or after this date.
**Key Points / Main Content**
* **UTI Mandate:**
* A UTI is required for all OTC derivative transactions.
* **Scope:**
* Applies to transactions for Rupee interest rate derivatives, forward contracts in Government securities, foreign currency derivatives, foreign currency interest rate derivatives, and credit derivatives, previously reported to CCIL-TR.
* The directions are applicable to OTC derivative transactions undertaken in terms of the specified "Governing Directions" as amended from time to time.
* **UTI Generation:**
* UTI generation will follow the waterfall mechanism outlined in Table 1, with the responsibility falling on different entities depending on the transaction's characteristics (e.g., whether it's reported only in India or also in a foreign jurisdiction).
* If a transaction is reported to CCIL-TR without a UTI, CCIL-TR will generate the UTI.
* UTI must adhere to the UTI Technical Guidance issued by CPMI-IOSCO.
* UTI consists of a maximum of 52 characters, including the Legal Entity Identifier (LEI).
* **Reporting:**
* Market participants must make reasonable efforts to obtain and report the UTI within the required deadline, especially when a foreign jurisdiction has a shorter reporting timeline.
* If unable to meet the deadline, the UTI must be submitted to CCIL-TR within five Mumbai business days from the transaction date.
* Amendments to a derivative contract that do not result in a new reportable contract do not require a new UTI. However, a lifecycle event (e.g. novation) will result in a need for a new UTI.
* CCIL will issue operating guidelines and reporting formats for reporting of UTI.
* **Effective Date:**
* The directions come into effect from January 01, 2027.
**Impact Analysis**
**Eligible Market Participants**
* **Impact:** Affected by the new UTI mandate.
* **Action Required:** Market participants must implement necessary arrangements to generate, obtain, and report UTIs for their OTC derivative transactions, as per the specified guidelines and timelines. They must ensure compliance with the UTI requirement for all transactions entered into on or after January 01, 2027.
Key Entities Referenced
Reserve Bank of India Act, 1934: The act under which the directions are issued, specifically citing sections 45W and 45U.
Unique Transaction Identifier (UTI): A unique identifier assigned to an OTC derivative transaction, which is the central focus of the directive.
Reserve Bank of India: The primary regulatory body issuing the directive.
Clearing Corporation of India Limited (CCIL-TR): Manages the Trade Repository to which OTC derivative transactions are reported and is involved in UTI generation.
भारतीय �र ज़वर् बैंक
RESERVE BANK OF INDIA
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 Annex.
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
िव�ीयबाज़ारिविनयमनिवभाग,केंद्रीयकायार्लयभवन, नौवी ंमंिजलशहीदभगतिसंहमागर्,फोटर्,मुंबई .भारत
फोन ( 2260 1000; Extn.: 5069, ईमेल
, –400001
Financial Markets Regulation Department, Central Office Building, 9th Floor, Shahid Bhagat Singh Marg, Fort, Mumbai – 400001. India
Tel: :(9911-2-222) )2260 1000; Extn.: 5069, e-m-ail-: ccggmmffmmrrdd@@rrbbii..oorrgg..iinn
िह�ी आसान है, इसका प्रयोग बढ़ाइए(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”):
a. Foreign Exchange Management (Foreign Exchange Derivative Contracts)
Regulations, 2000 (Notification no. FEMA.25/RB-2000 dated May 3, 2000) and
Master Direction – Risk Management and Inter-Bank Dealings (Notification no.
FMRD Master Direction No. 1/2016-17 dated July 05, 2016), as amended from
time to time.
b. Master Direction – Reserve Bank of India (Rupee Interest Rate Derivatives)
Directions, 2025 (Notification no. FMRD.DIRD.No.06/14.03.046/2025-26 dated
December 09, 2025), as amended from time to time;
c. Reserve Bank of India (Forward Contracts in Government Securities)
Directions, 2025 (Notification no. FMRD.DIRD.17/14.03.042/2024-25 dated
February 21, 2025), as amended from time to time.
d. Master Direction – Reserve Bank of India (Credit Derivatives) Directions, 2022
(Notification no. FMRD.DIRD.11/14.03.004/2021-22 dated February 10, 2022),
as amended from time to time.
e. 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.
14. The UTI generating entity shall be determined as per the waterfall in Table 1
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 1) The CCP, if the CCP is
to the transaction. counterparty to the transaction.
2) The ETP, if the transaction is 2) Clearing Member, if a Clearing
executed on an ETP. Member is counterparty to the
transaction.
3) An entity as is mutually agreed 3) ETP, if the transaction is executed
between the counterparties. on an ETP.
4) CCIL-TR. A. If a foreign jurisdiction has a
sooner reporting timeline1
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
1 The jurisdiction with the sooner reporting deadline will be identified as per the order of UTI Regulatory
Reporting Deadlines identified in the FAQs (CDIDE/2024/77) dated October 28, 2024 published by the
Regulatory Oversight Committee (ROC).
2or 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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