Changes to the OTC Derivatives Reporting Regime Commencing on 21 October 2024

14 May 2024

Overviews of OTC Derivatives Reporting Regime

In Singapore, specified financial institutions which are licensed in Singapore and significant derivatives holders are subject to reporting obligations relating to over-the-counter derivatives contracts provided in Part 6A of the Securities and Futures Act 2001 (“OTC Derivatives Reporting Regime“), unless they are exempted. Details of the reporting obligations are set out in the Securities and Futures (Reporting of Derivatives Contracts) Regulations 2013 (“SF(RDC)R“).

Persons which are subject to the OTC Derivatives Reporting Regime (“reporting entities“) must report information prescribed in the SF(RDC)R to a licensed trade repository or licensed foreign trade repository within two business days of the execution of the “reportable derivatives contracts”. The “reportable derivatives contracts” include interest rate derivatives contracts, credit derivatives contracts, foreign exchange derivatives contracts, commodity derivatives contracts and equity derivatives contracts which are booked in or traded in Singapore.

Changes to OTC Derivatives Reporting Regime on 21 October 2024

On 21 October 2024, the SF(RDC)R will be revised to implement the key changes to the OTC Derivatives Reporting Regime set out below. On 31 May 2024, the Monetary Authority of Singapore (“MAS“) issued the finalised “Guidelines to the Securities and Futures (Reporting of Derivatives Contracts) Regulations 2013” (“New OTC Guidelines“) that provide further guidance on the updated OTC Derivatives Reporting Regime.

Reporting of UTI. Reporting entities will be required to report a unique transaction identifier (“UTI“) that is uniquely assigned to each reportable derivatives contract, and which should remain as the identifier throughout the life of a contract. To avoid the generation and reporting of multiple UTIs for the same reportable derivatives contract, only one entity should be the UTI generating entity. Reporting entities should determine the UTI generating entity in accordance with the guidance set out in the New OTC Guidelines.
Changes to reportable data fields. Derivatives information to be reported for the reportable derivatives contracts are prescribed in the First Schedule to the SF(RDC)R (“reportable data fields“). Changes to the reportable data fields on 21 October 2024 include: (i) the adoption of a global unique product identifier (“UPI“) to denote the product types of the reportable derivatives contracts; (ii) inclusion of data fields for “Package Identifier”, “Asset Class” and “Contract Type”; (iii) reporting of the direction of the trade from the perspective of the reporting entity; and (iv) data fields relating to collateral and margin. The New OTC Guidelines contain explanatory notes which describe how the respective reportable data fields should be reported in different scenarios. In some cases, the explanatory notes may provide examples of specified derivatives contracts for which a data field is required or not required to be reported.
Adoption of ISO 20022 Standard. From 21 October 2024, reporting entities are expected to adopt the ISO 20022 XML format when reporting reportable derivatives contracts.
Re-reporting of reportable derivatives contracts. The New OTC Guidelines provide that with effect from 21 October 2024, existing reporting entities will be required to re-report the details of all outstanding specified derivatives contracts that have a remaining maturity of at least six months as at 21 October 2024 (i.e. maturing on or after 21 April 2025) (“Re-reportable Contracts“). This requirement applies to all Re-reportable Contracts that were previously reported or would have been required to be reported under the SF(RDC)R before it was amended on 21 October 2024. All Re-reportable Contracts must be reported by 21 April 2025.

MAS has also published updates to FAQs on the Securities and Futures (Reporting of Derivatives Contracts) Regulations 2013 to provide further guidance on the implementation of the abovementioned changes.

You may also wish to read our February 2024 Legal Update titled “Call to Action: Preparing for Changes to the OTC Derivatives Reporting Regime” for practical issues that a reporting entity should consider in preparing to comply with these changes to the OTC Derivatives Reporting Regime.

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