Hong Kong: Adopted enhancements to OTC Derivatives Reporting Regime including crypto currencies

On 29 September 2024, the Hong Kong Monetary Authority (HKMA) and the Securities and Futures Commission (SFC) published the results of the proposed enhancements to Hong Kong's over-the-counter (OTC) derivatives reporting regime. The proposed enhancements mandate the use of Unique Transaction Identifiers (UTIs) and Unique Product Identifiers (UPIs), in conjunction with the reporting of Critical Data Elements (CDEs) for transactions involving OTC derivatives. A number of respondents expressed concern about the reporting of data for newer products, such as digital assets, which may not fit within the traditional categories of assets. In order to address this issue, the HKMA and SFC have announced their intention to permit the use of the Digital Token Identifier (DTI) for the purpose of reporting transactions involving crypto-asset derivatives. Furthermore, the CDE requirements will be simplified, with the number of mandatory data fields reduced in order to reduce the reporting burden while maintaining regulatory effectiveness. The proposals were met with considerable support from respondents, who acknowledged the advantages of standardising reporting practices across jurisdictions. The targeted implementation of the aforementioned UTI and UPI reporting is 29 September 2025.