ASIC’s Transaction Reporting Rules (ASIC Rules) do not impose any obligation for matching or pairing trade reports between counterparties. Neither the ASIC Rules nor Regulatory Guide 251 (RG 251), require that the data reported by one counterparty matches or pairs with the data reported by the other counterparty (whereas there is a matching regime under EMIR Refit).
The closest mechanism to pairing under the ASIC Rules is the Unique Transaction Identifier (UTI) Waterfall under Rule 2.2.9. This is a mechanism through which both sides of a trade are expected to use the same identifier. RG 251 states that the UTI provides significant regulatory benefit in terms of matching both sides of the same transaction, including avoiding double counting in market metrics such as turnover and aggregate notional principal. To support this outcome, Rule 2.2.9 generally requires a reporting entity to generate a UTI and provide it to the other counterparty as soon as practicable. Section D of RG 251
