Over-the-counter (OTC) derivative transactions in India will require a Unique Transaction Identifier (UTI) from January 1, 2027, after the Reserve Bank of India (RBI) deferred the rollout by nine months to give market participants more time to upgrade systems and reporting processes, as per the final guidelines released on Wednesday.
The original implementation date of April 1 has been deferred following industry feedback. The revised timeline is aimed at providing sufficient time for market participants to build the required technical capabilities.
At present, all transactions in OTC markets—covering 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 (CCIL-TR). It has now been decided to mandate a UTI for all such transactions, the final guidelines said.
Importantly, the requirement will apply prospectively. Only OTC derivative contracts entered into on or after January 1, 2027, will need a UTI.
The RBI has retained the proposal for UTI generation responsibilities. The obligation will first lie with the central counterparty, where applicable, followed by electronic trading platforms, clearing members, or an entity mutually agreed upon by counterparties. If a trade is reported without a UTI, the Trade Repository operated by CCIL-TR will generate one. The delegation of UTI generation to third-party vendors using their own Legal Entity Identifier (LEI) is not permitted.
For cross-border transactions reportable in multiple jurisdictions, the framework provides flexibility. Where a foreign jurisdiction has an earlier reporting deadline, market participants must make reasonable efforts to comply, the guidelines said. The window to submit the final UTI has also been extended to five business days from the trade date, compared with two days proposed earlier. Reporting entities may also use temporary or interim UTIs if the final identifier is not immediately available.
Routine modifications to an existing derivative contract will not require a new UTI. However, if a transaction is replaced with an entirely new contract between the parties, a fresh identifier must be generated. Detailed operating guidelines and revised reporting formats will be issued by CCIL to support implementation.