The Reserve Bank of India (RBI) has decided to make Unique Transaction Identifier (UTI) mandatory for all transactions in the over-the-counter (OTC) derivatives market beginning April 1, 2026, as per an RBI’s draft circular.
Under the new framework, UTI will be implemented 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. The central bank has invited comments with respect to this circular from banks, market participants and other interested parties by November 14, 2025.
For context, UTI is one of the key data elements identified globally for reporting of OTC derivative transactions, alongside the Legal Entity Identifier (LEI). For context, while the LEI uniquely identifies the counterparties to an OTC derivative transaction, the UTI serves as a unique and paired code for identifying a derivatives transaction, helping to identify and resolve potential reporting errors.
RBI Directions For UTI Generation And Structure
As per the draft circular, UTI will be mandatorily generated for all transactions in OTC derivatives market in accordance with guidance issued in February 2017 by the Committee on Payments and Market Infrastructures (CPMI) – International Organisation of Securities Commissions (IOSCO).
Notably, a UTI, which will will be unique to a derivative transaction throughout its lifecycle, will have a maximum of 52 characters consisting of the LEI of the generating entity, followed by a unique identifier.
The RBI said that the UTI generating entity will be determined using a “waterfall table”, where the responsibility is assigned to the next entity in the table if the identified UTI generating entity either fails or is unwilling to generate the UTI.
CCIL-TR To Generate UTI If Need Arises
In terms of the waterfall table, 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.
For transactions that are reportable in India and in one or more foreign jurisdictions (with the foreign jurisdiction having a shorter reporting window), 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, they 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.
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 that results in the creation of a new reportable derivative contract, as per extant reporting…
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