RBI Mandates Unique Transaction Identifier for OTC Derivatives

Circular No. RBI/2025-26/222 CO.FMRD.MIOD.No.8/11.01.057/2025-26, Dated: 18.02.2026

The Reserve Bank of India (RBI) has mandated the generation and reporting of a Unique Transaction Identifier (UTI) for all Over-the-Counter (OTC) derivative transactions undertaken under specified governing directions.

The framework aims to enhance transparency, traceability, and regulatory oversight in derivative markets.

1. Compliance with Global Technical Standards

The UTI framework must comply with CPMI-IOSCO technical guidance, ensuring alignment with international standards for trade reporting and risk monitoring.

Key requirement:

Each UTI must remain unique throughout the lifecycle of the derivative contract
It must enable consistent identification of transactions across reporting entities and repositories

2. Scope of Applicability

The directions apply to:

All OTC derivative transactions
Undertaken under specified RBI governing directions
Reportable to authorised trade repositories

This ensures comprehensive coverage of derivatives outside exchange-traded platforms.

3. Waterfall Mechanism for UTI Generation

The framework prescribes a waterfall mechanism for generation of UTIs, specifying:

Responsibility for generating the UTI
Hierarchy of counterparties responsible if the primary entity does not generate it
Standardised process to avoid duplication or inconsistency

This ensures clarity on responsibility and seamless reporting.

4. Reporting and Lifecycle Requirements

The directions also clarify:

Reporting timelines for submission of UTIs
Lifecycle treatment of UTIs across amendments, novations, and terminations
Compliance and reconciliation requirements

Entities must ensure accurate and timely reporting of UTIs across the entire contract lifecycle.

5. Effective Date

The directions will come into force from 1 January 2027

Entities are expected to align systems and processes in advance of implementation.

6. Key Takeaway

RBI’s UTI framework introduces a globally aligned system for unique identification and reporting of OTC derivative transactions, strengthening transparency, lifecycle tracking, and regulatory monitoring, with mandatory compliance from 1 January 2027.