HomeCirculars › RBI/2025-26/222

Unique Transaction Identifier for OTC Derivative Transactions

Current · Source: Reserve Bank of India · RBI/2025-26/222 · issued 18 Feb 2026 · ~1 min read
Quick answerRBI mandates Unique Transaction Identifier (UTI) for OTC derivative transactions under specified Governing Directions to enhance market transparency and regulatory oversight.
The rule, in the simplest words
How it plays out — a real example

As a forex & trade-finance officer in Indore, Rohan must ensure that all OTC derivative transactions are assigned a Unique Transaction Identifier (UTI) and reported to the Trade Repository. This will help the Reserve Bank of India to obtain a comprehensive view of the OTC derivatives market and enhance market transparency and regulatory oversight.

What changed

RBI introduces Unique Transaction Identifier (UTI) for OTC derivative transactions under specified Governing Directions (e.g., FEMA, Rupee Interest Rate Derivatives, etc.) to be reported to Trade Repository managed by Clearing Corporation of India Limited (CCIL-TR). UTI will be generated in accordance with the UTI Technical Guidance issued by Committee on Payments and Market Infrastructures (CPMI) - International Organisation of Securities Commissions (IOSCO) in February 2017.

What it means for you

This change will enable policy makers to obtain a comprehensive view of the OTC derivatives market, enhancing market transparency and regulatory oversight. Banks and lenders will need to ensure compliance with the new regulations.

What you must do

Who it affects

Banks, Lenders, OTC derivative market participants

❓ Common questions

What is Unique Transaction Identifier (UTI)?

UTI is a unique identifier assigned to an OTC derivative transaction under specified Governing Directions to enhance market transparency and regulatory oversight.

Who will generate UTI?

The UTI generating entity will be determined as per the waterfall in Table 1, with responsibility assigned to the next entity in the waterfall in case the identified UTI generating entity is unable or unwilling to generate the UTI.

When will the new regulations come into effect?

The new regulations will come into effect from January 01, 2027, and will be applicable to OTC derivative transactions entered into on or after the date the directions come into effect.

📜 Read the original circular — full text as issued by RBI
RBI/2025-26/222 CO.FMRD.MIOD.No.8/11.01.057/2025-26 February 18, 2026 To All eligible market participants Madam / Sir, Unique Transaction Identifier for OTC Derivative Transactions The Unique Transaction Identifier (UTI) has been conceived as one of the key data elements identified globally for reporting over-the-counter (OTC) derivative transactions with a view to enable policy makers to obtain a comprehensive view of the OTC derivatives market. 2. At present, 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 are reported to the Trade Repository managed by Clearing Corporation of India Limited (CCIL-TR). It has now been decided to mandate UTI for all such transactions. A framework for the implementation of UTI for OTC derivative transactions, is enclosed at Annex . 3. The directions shall come into effect from January 01, 2027 and shall be applicable to OTC derivative transactions entered into on or after the date the directions come into effect. 4. These directions have been issued in exercise of the powers conferred under section 45W of the Reserve Bank of India Act, 1934 read with section 45U of the Act and of all the powers enabling it in this behalf. Yours faithfully, (Dimple Bhandia) Chief General Manager (Annex to circular CO.FMRD.MIOD.No.8/11.01.057/2025-26 dated February 18, 2026 on Unique Transaction Identifier for OTC Derivative Transactions) 1. The directions shall be applicable to all OTC derivative transactions undertaken in terms of the following directions (hereinafter “Governing Directions”): Foreign Exchange Management (Foreign Exchange Derivative Contracts) Regulations, 2000 ( Notification no. FEMA.25/RB-2000 dated May 3, 2000 ) and Master Direction – Risk Management and Inter-Bank Dealings ( Notification no. FMRD Master Direction No. 1/2016-17 dated July 05, 2016 ), as amended from time to time. Master Direction – Reserve Bank of India (Rupee Interest Rate Derivatives) Directions, 2025 ( Notification no. FMRD.DIRD.No.06/14.03.046/2025-26 dated December 09, 2025 ), as amended from time to time; Reserve Bank of India (Forward Contracts in Government Securities) Directions, 2025 ( Notification no. FMRD.DIRD.17/14.03.042/2024-25 dated February 21, 2025 ), as amended from time to time. Master Direction – Reserve Bank of India (Credit Derivatives) Directions, 2022 ( Notification no. FMRD.DIRD.11/14.03.004/2021-22 dated February 10, 2022 ), as amended from time to time. Any other Direction(s), as may be specified by the Reserve Bank. 2. Unique Transaction Identifier (UTI), a unique identifier assigned to an OTC derivative transaction, shall be generated / reported for all transactions in OTC derivatives market undertaken in terms of the Governing Directions. The directions shall be applicable to OTC derivative transactions entered into on or after the date the directions come into effect. 3. UTI shall be generated in accordance with the UTI Technical Guidance issued by the Committee on Payments and Market Infrastructures (CPMI) - International Organisation of Securities Commissions (IOSCO) in February 2017. It shall have a maximum of 52 characters comprising the Legal Entity Identifier (LEI) of the generating entity followed by a unique identifier and shall be unique to a derivative transaction throughout its lifecycle. 4. The UTI generating entity shall be determined as per the waterfall in Table 1 with the responsibility of UTI generation assigned to the next entity in the waterfall in case the identified UTI generating entity is unable or unwilling to generate the UTI. In terms of the waterfall, 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. Table 1: Generation of UTI
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2025-26/222 · issued 18 Feb 2026. The plain-English explanation above is BankPulse’s own independent summary.
🧰 Tools — save, print, templates & related
Who does what — compliance checklist
⚙️ Operations
  • Report UTI to Trade Repository managed by Clearing Corporation of India Limited (CCIL-TR)
📜 Compliance
  • Generate Unique Transaction Identifier (UTI) for all OTC derivative transactions
  • Ensure compliance with the new regulations
Grouped from the action items above — a single circular may involve more than one team.
Worked example & action-note template

Example: if you are a Compliance officer at a bank this circular applies to (Banks, Lenders, OTC derivative market participants), your first concrete step on “Unique Transaction Identifier for OTC Derivative Transactions” is: “Generate Unique Transaction Identifier (UTI) for all OTC derivative transactions” (RBI issued this 18 Feb 2026).

  1. Circular: RBI/2025-26/222 -- Unique Transaction Identifier for OTC Derivative Transactions
  2. Issued: 18 Feb 2026
  3. Action required: Generate Unique Transaction Identifier (UTI) for all OTC derivative transactions
  4. Action required: Report UTI to Trade Repository managed by Clearing Corporation of India Limited (CCIL-TR)
  5. Action required: Ensure compliance with the new regulations
  6. Owner: ____________ Target date: ____________
  7. Board/committee approval needed? Y / N
  8. Evidence filed in compliance register on: ____________
Built only from this circular’s own published fields — not legal advice; always confirm against the official RBI source.

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BankPulse Compliance Evidence Pack — generated 03 Aug 2026 · status cross-checked against RBI’s official withdrawal register (refreshed weekly).
Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13307&Mode=0 — Plain-English summary by BankPulse (bankpulse.ai), reviewed by our expert reviewer, CA Amit Jain. Independent platform, not affiliated with the Reserve Bank of India; is our own plain-English paraphrase, not RBI’s original wording.
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