RBI: Directions On Unique Transaction Identifier For OTC Derivatives (Effective January 1st, 2027)

The Reserve Bank of India (“RBI”) has operationalised the Unique Transaction Identifier framework through a circular titled “Unique Transaction Identifier for OTC Derivative Transactions”, issued under section 45W of the Reserve Bank of India Act, 1934, on February 18th, 2026, with directions annexed, which shall come into effect on January 1st, 2027 and be applicable to all over-the-counter derivative transactions entered into on and after January 1st, 2027 (“RBI UTI Directions”).

I. Background

Over-the-counter (“OTC”) derivatives form a major component of the Indian derivatives market and are widely used for risk management, hedging and investment. These products include, inter alia, rupee interest rate derivatives, foreign currency and foreign currency interest rate derivatives, and credit derivatives. Such transactions are undertaken under various RBI directions, including the Master Direction – Risk Management and Inter-Bank Dealings, the RBI (Rupee