On Aug. 11, 2025, HK SFC issued circular reminding licensed corporations about updated technical specifications for OTC derivatives trade reporting.
Updated technical specifications will be effective Sep. 22, 2025, ahead of implementation of reporting requirements on UTI, UPI, and CDE on Sep. 29, 2025.
Licensed corporations that may be subject to the mandatory reporting obligation are advised to refer to the HKMA letter above, dated Aug. 8, 2025.
On Mar. 22, HKMA, HK SFC proposed mandatory use of UTI, UPI.
HKMA, HK SFC issued consultation on enhancing OTC derivatives reporting regime, further to consultation on revising the list of designated jurisdictions for masking relief.
To align with global standards, HK SFC, HKMA conducted a consultation in Apr. 2019.
One of the proposed requirements was identification of transactions submitted to Hong Kong Trade Repository for reporting obligation by a unique transaction identifier (UTI).
Consultation
Proposes to implement the mandatory use of UTI in Hong Kong on Sep. 29, 2025.
Reporting entities may report the existing trade identifiers until implementation date.
They shall provide the unique product identifier (UPI) for the underlying derivatives of each submitted reportable transaction to the Hong Kong Trade Repository (HKTR).
Adopt the UPI technical guidance and the ISO 4914 standard for UPI structure/format.
Mandating reporting of critical data elements (CDE)/adoption of ISO 20022 standard.
Concluded no change will be made to the current designated list for the masking relief.
Effectiveness
Consultation is open for opinions which shall be submitted by May 17, 2024.
Respondents generally supported the proposals, though some of the proposals were eventually fine-tuned based on provided feedback to facilitate smooth implementation.
Concluded list of data elements for mandatory reporting to be published in gazette.
Reporting entities must review updated standards and prepare for new requirements.
Updated version of administration and interface development guide has been released.
Updates to the supplementary reporting instructions (SRI) for OTC derivatives transactions and frequently asked questions will also be published in due course.
HKTR system launch confirmed Sep. 29, 2025, testing environment from Jun. 2025.
Dec. 2024 Circular Issued
On Dec. 20, 2024, HKMA, HK SFC issued circular re frequently asked questions(FAQs) and the supplementary reporting instructions for OTC derivative transactions (SRI).
Updates cover requirements for unique transaction identifier, unique product identifier, critical data elements reporting, and ISO 20022 standard adoption after consultation.
Licensed corporations subject to the mandatory reporting obligations must comply.
Both revised FAQs and SRI take effect from Sep. 29, 2025.
Mar. 2025 Simulation Test Arrangements
On Mar. 21, 2025, HKMA said testing environment will be available from Jun. 2, 2025.
This testing environment will allow reporting entities to simulate reporting based on the updated Administration and interface development guide (AIDG).
All regulated entities subject to mandatory reporting are required to complete the simulation test and submit a readiness declaration form by Sep. 12, 2025.
Entities intending to report through agents must ensure that their agents meet all HKTR technical requirements and conduct submission testing in advance.
Authorized institutions reporting via agents should be aware that this may constitute an outsourcing arrangement requiring prior approval from the HKMA.
Apr. 2025 Updated Versions of Guide, FAQs
On Apr. 25, 2025, HK SFC, HKMA published latest versions of AIDG, FAQs, and SRI to support enhancements to Hong Kong’s OTC derivatives reporting requirements.
These updates aim to clarify industry participants’ questions and address concerns regarding the implementation of the enhanced reporting requirements.
HK GVT also gazetted a notice to give legal effect to the mandatory data elements.
The new documents will take effect on Sep. 29, 2025.
May 2025 Guide Updated
On May 19, 2025, HKMA published latest versions of AIDG, SRI, containing updates on ISO 20022 standard implementation timeline; HKTR system launch date for ISO 20022 standard rollout is advanced to Sep. 22, 2025, providing industry with additional one-week cushion period prior to the regulatory implementation date of Sep. 29, 2025.
Reporting entities not required to begin reporting in ISO format until Sep. 29, 2025; those switching to ISO format during buffer considered compliant with pre-rollout rule; entities should not report same trades in pre-ISO system if reporting in new format.
May 21, 2025 Implementation of ISO 20022
On May 21, 2025, HK SFC advised licensed corporations that HKTR has announced the HKTR system will be ready for implementation of ISO 20022 starting Sep. 22, 2025.
This provides a one-week period to facilitate reporting entities’ preparation for their migration process where needed, ahead of the compliance date of Sep. 29, 2025.
Jun. 2025 Update of Operating Procedures
On Jun. 10, 2025, HKMA issued Operating procedures for HKTR - RPT - user manual for participants; the new version includes minor editorial updates to UI function screenshots and report field names alignment; was effective from May 29, 2025.
Jul. 2025 Reminder and Preparations
On Jul. 31, 2025, HKMA issued a reminder to reporting entities on the upcoming implementation of Hong Kong's new OTC derivatives reporting requirements.
Reminded that mandatory use of UTI, UPI, CDE reporting and the adoption of the ISO 20022 XML message standard will take effect on Sep. 29, 2025.
Urged all reporting entities to expedite the necessary preparatory work in order to comply with the reporting requirements, including a comprehensive review of the revised reporting standards, execution of required system upgrades, and staff training.
Early system availability will be enabled on Sep. 22, 2025, so reporting entities will have the option to make early transition to the ISO standard from that day onwards.
Aug. 8, 2025 Revised Guide Published
On Aug. 8, 2025, HKMA published the latest version 1.0.3 AIDG ISO 20022 standard.
The updated AIDG will be effective from Sep. 29, 2025.
Aug. 8, 2025 OTC Reporting Specifications
On Aug. 8, 2025, HKMA published a letter entitled OTC Derivatives Trade Repository of the HKMA - Updated Technical Specifications for Reporting, on previously announced changes to reporting procedures including a move to the AIDG ISO 20022 standard.
Letter confirmed revised AIDG will start to apply from Sep. 22, 2025 for this category, with updates in the AIDG version 1.0.3, effective Aug. 16, 2025, in UAT environment.
This will allow for the early transition to the ISO standard from Sep. 22, 2025 onward.
Regulated entities subject to these reporting requirements must complete a prescribed simulation test, followed by readiness declaration form, on or before Sep. 12, 2025.
Aug. 11, 2025 HK SFC OTC Reporting Reminder
On Aug. 11, 2025, HK SFC issued circular reminding licensed corporations about updated technical specifications for OTC derivatives trade reporting.
Updated technical specifications will be effective Sep. 22, 2025, ahead of implementation of reporting requirements on UTI, UPI, and CDE on Sep. 29, 2025.
Licensed corporations that may be subject to the mandatory reporting obligation are advised to refer to the HKMA letter above, dated Aug. 8, 2025.
