Reporting Consultation Conclusions

On 26 September 2024, around six months following the date of the publication of the Joint further consultation on enhancements to the OTC derivatives reporting regime for Hong Kong to mandate - (1) the use of Unique Transaction Identifier, (2) the use of Unique Product Identifier and (3) the reporting of Critical Data Elements and Joint consultation conclusions on revising the list of designated jurisdiction for the marking relief (the “Consultation”), as they had promised, the HKMA and SFC released the Joint further consultation conclusions on enhancements to the OTC derivatives reporting regime for Hong Kong to mandate - (1) the use of Unique Transaction Identifier; (2) the use of Unique Product Identifier and (3) the reporting of Critical Data Elements.

In a nutshell, the proposals in the Consultation (as discussed in our Alert were largely reaffirmed and the proposed implementation date of 29 September 2025 was confirmed. Parties thus have a runway of one year to implement the proposals.