On January 9, ISDA, the Alternative Investment Management Association (AIMA) and the European Banking Federation (EBF) submitted a joint response to the European Commission (EC) consultation on the best way to identify over-the-counter (OTC) derivatives for transparency requirements under the Markets in Financial Instruments Regulation (MIFIR).
The associations highlight their preference for the identification of OTC derivatives using the unique product identifier (UPI) (ISO 4914) in MIFIR regulatory technical standard (RTS) 2, augmented by a number of other fields to ensure optimal granularity. RTS 2 sets out the technical detail of transparency requirements under MIFIR. The associations state that the most efficient way for users of transparency and consolidated tape data to understand the tenor of instruments covered by these requirements would be for market participants to report the effective date (among the additional fields needed), which along with the time stamp of the trade, would allow approved publication arrangements to calculate the tenor for these users. The associations also suggest that the EC should conduct a cost-benefit analysis regarding the use of the UPI as the basis for MIFIR transaction reporting requirements.
MIFIR currently requires international securities identification numbering as implemented in the EU for OTC derivatives as the basis for transparency and transaction reporting requirements, but this approach has been sub-optimal in some asset classes, particularly interest rate derivatives.
Documents (1) for ISDA, AIMA, EBF Respond to EC on Unique Product Identifier
Latest
Updated OTC Derivatives Compliance Calendar
ISDA has updated its global calendar of compliance deadlines and regulatory dates for the over-the-counter (OTC) derivatives space.
Episode 60: Modelling Margin
The ISDA Standard Initial Margin Model has proved to be one of the most consequential industry models ever developed. The Swap talks with two industry veterans involved in its development. Please view this page via Chrome to access the recording.
ISDA Wins Digital Solution of the Year Award
ISDA has won Digital Solution of the Year at the GlobalCapital Global Derivatives Awards 2026 for the ISDA Digital Regulatory Reporting (DRR) initiative and the ISDA Notices Hub. The award recognizes ISDA’s continued work to develop mutualized digital solutions that...
ISDA Launches Digital Emissions Definitions
ISDA has launched a natively digital version of its documentation for emissions allowance transactions, enabling the framework to be updated more efficiently as emissions trading systems (ETSs) evolve. The 2026 ISDA Emissions Transactions Definitions provide standardized documentation for physically settled...
