| Country |
Regulatory Body |
Summary of Current Trade Reporting Rules |
| Argentina |
Comisión Nacional de Valores (CNV) |
Over-the-counter (OTC) derivative trade reporting framework is currently under development and there are limited reporting requirements. |
| Australia |
Australian Securities and Investments Commission (ASIC) |
ASIC Derivative Transaction Rules (Reporting) 2024 currently govern derivative transaction reporting
Key updates in 2024:
1. Alignment with ISO 20022 and other international standards for data elements
2. Unique Product Identifier (UPI) required for each prodcut, rath than relying on ISDA taxonomy
3. Unique Transaction Identifier (UTI) required for each trade
4. Reporting deadline was generally increased from T+1 to T+2 |
| Brazil |
Comissão de Valores Mobiliários (CVM), Banco Central do Brasil |
OTC derivative transactions must be reported to an established and regulated Brazilian Entity.
Reporting is typically required on same day and requires simultaneous trade reports from both parties.
BM&FBOVESPA typically acts as the primary trade repostiroy for derivatives, futures, and options. |
| Canada |
Canadian Securities Administrators (CSA) |
CSA re-write for Canada trade reporting rules will be implemented on July 25, 2025
Key updates include:
1. Harmonization of the Unique Transaction Identifier (UTI) with global standards
2. Unique Product Identifier (UPI) required for all asset classes
3. Derivatives dealers to report valuation, collateral, and margin data
4. ISO 20022 was not included, meaning we may expect another re-write in 2026 |
| China |
CSRC, People’s Bank of China (PBOC) |
As of 2023, the China Securities Regulatory Commission (CSRC) established requirements for local securities companies to report derivatives trades to trade repositories.
This has been an effort to align more with the G20 initiative, but does not include critical items like harmonization of Unique Transaction Identifier (UTI) and only covers specific asset classes (i.e., equities) |
| European Union |
European Securities and Markets Authority (ESMA) + national competent authorities |
The European Market Infrastructure Regulation (EMIR) trade reporting requirements mandate that all derivative transactions, both over-the-counter (OTC) and exchange-traded, must be reported to a trade repository.
Following the "EMIR Refit" of 2019, there was another update in 2024 with critical updates:
1. Reports of margin updates (collateral) must be made daily
2. Mandatory reporting requirements of OTC and exchange-traded derivatives for non-financial counterparties who are delegating trades to financial counterparties |
| France |
AMF (Autorité des marchés financiers), under ESMA/EMIR |
France is governed by EMIR derivative trade reporting requirements. The rules are enforced locally by the AMF.
In addition, the AMF has local rules for equity derivatives transactions involving France-based issuer's shares. |
| Germany |
BaFin, under ESMA/EMIR |
Germany is governed by EMIR derivative trade reporting requirements. The rules are enforced locally by the Federal Financial Supervisory Authority, BaFin.
Foreign direct investments and related transactions have special local requirements that are covered under the German Foreign Trade and Payments Ordinance. |
| India |
Reserve Bank of India (RBI) and Securities and Exchange Board of India (SEBI) |
Banks and primary dealers acting as market makers have a requirement to report trades to the Clearing Corporation of India Limited (CCIL), the country's authorized Trade Repository.
Overall, India's requirements are not as extensive as other G20 countries. For example, Forwards and Swaps need to be reported daily while Options can be reported weekly. |
| Indonesia |
Bank Indonesia |
Under the Indonesian Banking Act, Bank Indonesia maintains requirements for domestic banks to report Foreign Exchange (FX) and interest rate derivatives.
However, Bank Indonesia does not currently issue any guidance for domestic banks to report their over-the-counter (OTC) derivatives to offshore Trade Repositories (TRs). |
| Italy |
CONSOB, under ESMA/EMIR |
Italy is governed by EMIR derivative trade reporting requirements. The rules are enforced locally by CONSOB.
CONSOB plays a critical role in ensuring transparency and integrity in the Italian derivatives market by setting position limits and providing regulatory oversight/enforcement. |
| Japan |
Financial Services Agency (JFSA) |
In April 2024, the JFSA revised its reporting requirements for OTC derivatives.
Critical updates include:
1. Mandatory reporting to Trade Repositories. Previously, this was not mandatory.
2. Expanded data fields (139 fields now required) and ISO20022 messaging standards
3. Unique Transaction Identifiers (UTI) and Unique Product Identifiers (UPI) are now required |
| Mexico |
Comisión Nacional Bancaria y de Valores (CNBV) and Banco de México |
Reporting requirements apply to some asset classes, including over-the-counter (OTC) equity derivatives, swaps, forwards, and options.... Authorized reporting entities include banks, broker-dealers, pension funds, and other financial institutions. These authorized entities must report all trades to Banxico's Domestic Trade Repository.
The rules were most recently updates in January 2025. |
| Russia |
Bank of Russia |
All over-the-counter (OTC) derivatives must be reported to a Russian Trade Repository. The NSD (National Settlment Depository) is the large trade repository. |
| Saudi Arabia |
Saudi Central Bank (SAMA), Capital Market Authority (CMA) |
SAMA requires that all licensed banks must report OTC derivatives trades for the following asset classes: Foreign Exchange, Interest Rates, Equities, Credit, Commodities.
Both OTC and exchange-traded derivatives must be reported. |
| South Africa |
Financial Sector Conduct Authority (FSCA), South African Reserve Bank (SARB) |
As of November 2024, Strate, the central securities depository has been granted the first Trade Repository (TR) license by the FSCA.
Critical reporting requirements include:
1. Common data fields: UTI (Unique Transaction Identifier), UPI (Unique Product Identifier), and LEI (Legal Entity Identifier)
2. Asset classes: all OTC derivatives asset classes (FX, interest rate, credit, equity, commodity) |
| South Korea |
Financial Services Commission (FSC), Financial Supervisory Service (FSS) |
The Financial Supervisory Service (FSS) enforces the reporting rules as defined by the Finanical Services Commission (FSC).
Under the latest guidance (2022), OTC derivatives must be reported to a Trade Repostiory (TR) for asset classes including equities, credit, commodities, FX, and interest rates.
In Q4 2025 it is expected that UTI (Unique Transaction Identifier), UPI (Unique Product Identifier), and other Critical Data Elements (CDE) will be added to the list of requirements.
Notably, non-compliance can currently be met with fines of up to KRW 100 Million (~USD 73,000). |
| Turkey |
Capital Markets Board of Turkey (CMB) |
As of 2020, licensed financial institutions (i.e., banks, brokers) and turkish-resident counterparties must report all OTC (over-the-counter) derivatives to a domestic TR (trade repository).
In-scope asset classes include: FX (Foreign Exchange), equity, interest rates, commodities, and credit. |
| United Kingdom |
Financial Conduct Authority (FCA) |
The UK has adapted the EU EMIR rules ("UK EMIR") post-brexit.
In 2024, the UK EMIR "Refit" was implemented to align with CPMI-IOSCO data standards.
Key reporting requirements changes are below:
1. Critical data elements (CDE) on all transactions including, Unique Transaction Identifier (UTI) and Unique Product Identifier (UPI)
2. Transaction lifecycle events, collateral, and valuation reports |
| United States |
CFTC (OTC swaps), SEC (equity/credit security-based swaps) |
Reporting parties include: swap dealers (SDs), swap execution facilities (SEFs), major swap participants (MSPs), and designated contract markets (DCMs)
Critical data elements (CDE) are aligned to CPMI-IOSCO standards, meaning Unique Product Identifier (UPI), Unique Transaction Identifier (UTI), LEIs, and 78 other fields are required.
The latest CFTC update was in December 2024 which was Phase 2 of the 2022 rewrite. |
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