RBI Mandates Unique Transaction Identifier for OTC Derivatives

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  • Last Updated on 20 February, 2026

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RBI Unique Transaction Identifier

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.

Click Here To Read The Full Circular

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Author: Taxmann

Taxmann Publications has a dedicated in-house Research & Editorial Team. This team consists of a team of Chartered Accountants, Company Secretaries, and Lawyers. This team works under the guidance and supervision of editor-in-chief Mr Rakesh Bhargava.

The Research and Editorial Team is responsible for developing reliable and accurate content for the readers. The team follows the six-sigma approach to achieve the benchmark of zero error in its publications and research platforms. The team ensures that the following publication guidelines are thoroughly followed while developing the content:

  • The statutory material is obtained only from the authorized and reliable sources
  • All the latest developments in the judicial and legislative fields are covered
  • Prepare the analytical write-ups on current, controversial, and important issues to help the readers to understand the concept and its implications
  • Every content published by Taxmann is complete, accurate and lucid
  • All evidence-based statements are supported with proper reference to Section, Circular No., Notification No. or citations
  • The golden rules of grammar, style and consistency are thoroughly followed
  • Font and size that's easy to read and remain consistent across all imprint and digital publications are applied