**Executive Summary**
This document from the Reserve Bank of India mandates the use of Unique Transaction Identifiers (UTI) for all Over-the-Counter (OTC) derivative transactions. This is to enable policymakers to have a comprehensive view of the OTC derivatives market. The directions are effective from January 01, 2027, and apply to transactions entered on or after that date.
**Key Points / Main Content**
* **General Provisions:**
* The directions apply to all OTC derivative transactions as defined under the specified "Governing Directions" (Foreign Exchange, Rupee Interest Rate Derivatives, Forward Contracts in Government Securities, Credit Derivatives).
* A Unique Transaction Identifier (UTI) must be generated/reported for all OTC derivative transactions.
* The UTI shall have a maximum of 52 characters and be unique throughout the derivative transaction's lifecycle.
* **UTI Generation:**
* The UTI generating entity is determined according to the specified waterfall table.
* If a transaction is reported to the Clearing Corporation of India Limited - Trade Repository (CCIL-TR) without the UTI, the CCIL-TR will generate it.
* **Reporting and Timelines:**
* Market participants should ensure the UTI is obtained and reported within the foreign reporting deadline for transactions reportable in both India and a foreign jurisdiction that have a sooner reporting timeline. If this is not possible, it should be submitted to CCIL-TR within five Mumbai business days.
* **UTI Management:**
* Amendments to a derivative contract post-reporting do not require a new UTI, but lifecycle events that create a new reportable derivative contract do require a new UTI.
* **Implementation:**
* CCIL shall issue operating guidelines and reporting formats.
* Market participants must ensure arrangements are in place for compliance.
**Impact Analysis**
**Eligible Market Participants**
* **Impact:** Required to implement UTI for OTC derivative transactions to comply with reporting requirements.
* **Action Required:** Develop and implement UTI generation and reporting processes in accordance with the framework, effective January 01, 2027.
**Clearing Corporation of India Limited (CCIL-TR)**
* **Impact:** Responsible for managing the Trade Repository, generating UTIs in certain cases, and issuing operating guidelines and reporting formats.
* **Action Required:** Update systems to accommodate UTI reporting and generation; issue necessary guidelines and formats.
Key Entities Referenced
Reserve Bank of India Act, 1934: The primary law granting powers exercised in issuing the directive related to UTI for OTC derivatives.
Unique Transaction Identifier (UTI): A unique identifier assigned to OTC derivative transactions, the central subject of the directive.
Reserve Bank of India: The regulatory body issuing the direction regarding UTI for OTC derivatives.
Clearing Corporation of India Limited (CCIL-TR): The Trade Repository responsible for managing and reporting OTC derivative transactions and for generating the UTI under certain circumstances.
Mumbai: The directive specifies business days in Mumbai for submitting the UTI to CCIL-TR.
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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