**Executive Summary**
This document from the Reserve Bank of India (RBI) outlines the implementation of the Unique Transaction Identifier (UTI) for Over-the-Counter (OTC) derivative transactions in India, with the goal of enhancing comprehensive oversight of the OTC derivatives market. It details the applicability, guidelines for UTI generation, and reporting requirements, and goes into effect on April 1, 2026. The circular provides an annex with a framework for UTI implementation.
**Key Points / Main Content**
* **Purpose and Scope:**
* Introduces the Unique Transaction Identifier (UTI) for OTC derivative transactions in India.
* Aims to enable policymakers to have a comprehensive view of the OTC derivatives market.
* Applies to Rupee interest rate derivatives, forward contracts in Government securities, foreign currency derivatives, foreign currency interest rate derivatives, and credit derivatives.
* **Definitions:**
* UTI: A unique identifier assigned to an OTC derivative transaction.
* Governing Directions: Refer to specific regulations and master directions related to foreign exchange, interest rate, and credit derivatives.
* **Applicability:**
* UTI is mandatory for all transactions in the OTC derivatives market as per the Governing Directions.
* **General Guidelines for UTI Generation:**
* UTIs shall be generated in accordance with the UTI Technical Guidance issued by CPMI-IOSCO.
* UTI consists of a maximum of 52 characters, including the Legal Entity Identifier (LEI) of the generating entity.
* The UTI generating entity is determined by a waterfall approach, with the Clearing Corporation of India Limited - Trade Repository (CCIL-TR) acting as a backstop.
* **Responsibilities and Reporting:**
* Market participants must make reasonable efforts to obtain and report the UTI promptly, especially for transactions reportable in both India and a foreign jurisdiction with a sooner timeline.
* Modifications to derivative contracts do not require a new UTI, but lifecycle events like novation do.
* The implementation of UTI will not change reporting mandates to CCIL-TR, and CCIL will issue revised reporting formats.
* **Effective Date:**
* The instructions come into effect from April 1, 2026.
**Impact Analysis**
**Eligible Market Participants**
* **Impact:** They are subject to new UTI generation and reporting requirements for OTC derivative transactions.
* **Action Required:**
* Understand and comply with the UTI generation and reporting guidelines.
* Implement necessary measures to ensure compliance.
* Adapt reporting systems to include UTI and follow CCIL's revised formats.
**Clearing Corporation of India Limited - Trade Repository (CCIL-TR)**
* **Impact:** The CCIL-TR serves as a backstop for UTI generation and is responsible for issuing revised reporting formats.
* **Action Required:**
* Prepare to generate UTIs if other entities are unable to.
* Issue revised reporting formats for OTC derivative transactions, incorporating UTI.
Key Entities Referenced
Unique Transaction Identifier (UTI): A key data element identified globally for reporting over-the-counter (OTC) derivative transactions.
Reserve Bank of India Act, 1934: The act under which the instructions in the circular are issued, specifically referencing sections 45W and 45U.
OTC Derivative Transactions: The type of financial transactions this policy concerns; specifically, derivatives traded over-the-counter.
Reserve Bank of India: The primary regulatory body issuing the circular.
Clearing Corporation of India Limited – Trade Repository (CCIL-TR): An entity involved in the generation of the UTI under certain conditions.
RESERVE BANK OF INDIA
FINANCIAL MARKETS REGULATION DEPARTMENT
9TH FLOOR, CENTRAL OFFICE, FORT
MUMBAI 400 001
To
All eligible market participants
Madam / Sir,
Unique Transaction Identifier for OTC Derivative Transactions in India - Draft
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. It has been decided to implement UTI for 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 in India. A
framework for the implementation of UTI for OTC derivative transactions, is enclosed
at Annex.
3. The instructions shall come into effect from April 01, 2026.
4. The instructions contained in this circular 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 Draft circular dated October 23, 2025 on Unique Transaction Identifier
for OTC Derivative Transactions in India)
1. Definition
1.1 “Unique Transaction Identifier” or "UTI” means a unique identifier assigned to
an OTC derivative transaction.
1.2 “Governing Directions” for an OTC derivative transaction means the following:
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, for foreign exchange derivatives.
b. Rupee Interest Rate Derivatives (Reserve Bank) Directions, 2019 (Notification
no. FMRD.DIRD.20/2019 dated June 26, 2019), as amended from time to time
and 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, for interest rate derivatives.
c. 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, for credit derivatives.
d. Other Direction(s), as may be issued by the Reserve Bank, in exercise of
powers vested in the Reserve Bank of India Act, 1934 or in the Foreign
Exchange Management Act, 1999, as the case may be, permitting the use of
OTC derivatives.
1.3 Words and expressions used, but not defined above, shall have the same
meaning as assigned to them in the Reserve Bank of India Act, 1934.
2. Applicability
2.1 UTI shall be mandatorily generated / reported for all transactions in OTC
derivatives market undertaken in terms of the Governing Directions.3. General Guidelines
3.1 UTI for transactions in OTC derivatives shall be generated in accordance with
the UTI Technical Guidance issued by Committee on Payments and Market
Infrastructures (CPMI) - International Organisation of Securities Commissions
(IOSCO) in February 2017. UTI shall have a maximum of 52 characters consisting of
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.
3.2 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 in India and
Transactions reportable only in
one or more foreign jurisdictions
India
1) The CCP, for transactions where the
1) The Central Counterparty
CCP is counterparty to the
(CCP), for transactions where
transaction;
the CCP is counterparty to the
transaction;
2) The Clearing Member, for
2) Electronic Trading Platform
transactions where Clearing Member
(ETP), for transactions
is counterparty to the transaction;
executed on an ETP;
3) ETP, for transactions executed on an
3) CCIL-TR.
ETP;
A. If a foreign jurisdiction has a sooner
reporting timeline1
1 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).4) Entity as determined by the
requirements in the foreign
jurisdiction.
B. If the foreign jurisdiction does not
have sooner reporting timeline
4) Identified entity, based on the
agreement between the
counterparties determining who
should generate the UTI;
5) CCIL-TR.
3.3 For transactions that are reportable in India and in a foreign jurisdiction, with
the foreign jurisdiction having a sooner reporting timeline, market participants may
undertake reasonable efforts to ensure that the UTI is obtained and reported in a timely
manner. In case the market participant is unable to report the UTI within the reporting
deadline, the market participant may obtain and submit the UTI to CCIL-TR within two
business days from the date of the transaction. The prior UTI generated by the CCIL-
TR will then be treated as a temporary / interim UTI.
3.4 Modification in any information pertaining to the derivative contract shall be
treated as an update and 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 result in the generation of
a new UTI.
3.5 The implementation of UTI shall not result in any change in OTC derivative
contracts mandated to be reported to CCIL-TR and market participants shall continue
reporting transactions as per the extant directions. CCIL shall issue the revised
reporting formats for reporting of OTC derivative transactions, including amendment
or modification therein, with UTI and the operating guidelines for the purpose.
3.6 Market participants shall ensure that necessary measures are put in place for
ensuring compliance with these instructions.
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