RBI Issues Draft Circular on Unique Transaction Identifier for OTC Derivative Transactions in India
The RBI has invited comments and suggestions on the Draft from banks, market participants and other stakeholders by November 14, 2025.
RBI - Circular - UTI - Taxscan
RBI - Circular - UTI - Taxscan
The Reserve Bank of India (RBI) has released a draft circular introducing the Unique Transaction Identifier (UTI) framework for over-the-counter (OTC) derivative transactions in India. The move is touted by the central bank as a measure to enhance transparency and regulatory oversight in the OTC derivatives market by providing a uniform identification system for all transactions.
The Draft Circular is annexed by the “Governing Directions” that lists the governing directions applicable to OTC derivative transactions. These include the Foreign Exchange Management (Foreign Exchange Derivative Contracts) Regulations, 2000, the Master Direction on Risk Management and Inter-Bank Dealings (FMRD Master Direction No. 1/2016-17), the Rupee Interest Rate Derivatives Directions, 2019, the Forward Contracts in Government Securities Directions, 2025, and the Credit Derivatives Directions, 2022.
The UTI is a globally recognised data element in derivative reporting and is in addition to the Legal Entity Identifier (LEI), which identifies counterparties to a transaction. While the LEI traces “who” is involved, the UTI identifies “which transaction” is being reported, allowing regulators to obtain an aggregated view of global OTC derivatives exposures.
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The identifier will contain a maximum of 52 characters, starting with the Legal Entity Identifier (LEI) of the entity responsible for creating it.
The task of generating the UTI will first fall to the Central Counterparty (CCP), followed by the Electronic Trading Platform (ETP) or the Clearing Member, depending on the nature of the transaction. If none of these entities is able to generate the identifier, it will be assigned by the Clearing Corporation of India Limited - Trade Repository (CCIL-TR) as the authority that will generate the identifier.
The RBI has proposed to make the UTI mandatory for all OTC derivative transactions in India, including Rupee interest rate derivatives, forward contracts in government securities, foreign currency derivatives, foreign currency interest rate derivatives and credit derivatives.
Each OTC derivative transaction governed by these directions must have a UTI generated and reported in accordance with the CPMI-IOSCO Technical Guidance of February 2017.
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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 shall result in the generation of a new UTI.
The RBI has invited comments and suggestions on the Draft from banks, market participants and other stakeholders by November 14, 2025. Feedback may be submitted to the Chief General Manager, Financial Markets Regulation Department, Reserve Bank of India, Central Office, Mumbai or through email with the subject line “Feedback on Draft Circular on Unique Transaction Identifier for OTC Derivative Transactions in India.”
The framework is set to take effect from April 1, 2026.
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