The Derivatives Service Bureau (DSB), the global golden source of reference data for OTC derivatives, today released data indicating industry readiness for the start of UK UPI (Unique Product Identifier) reporting on 30 September 2024 under revised UK EMIR rules. The UPI is reported to trade repositories so regulators can monitor the build-up of systemic risk across the OTC derivatives market. 

The UK will be the third jurisdiction to implement UPI reporting following the US and EU which went live on 29 January and 29 April 2024 respectively. The FCA and Bank of England published their joint rules on the revised derivatives reporting framework under UK EMIR in February 2023 with general alignment between the UK and EU approach, meaning the OTC ISIN is reported where the EMIR scope aligns with MiFIR, and the UPI reported for derivatives that fall under the wider scope of EMIR. Due to the complementary design of the two identifiers, the UPI is included in the OTC ISIN record to ensure global alignment.

The DSB’s user onboarding data reveals a large number of UK headquartered firms joined the UPI Service in readiness for the US and EU mandates coming into effect, with over 90% leveraging their OTC ISIN connectivity to streamline UPI integration. As a result of the advanced preparation, the DSB is noticing lower uptake in onboarding in the weeks leading up to the UK mandate. 

To date, over 390 firms have subscribed to the UPI Service on a fee-paying basis, including 157 programmatic users. Approximately 15% of those organisations are UK headquartered. Quarterly updates on UPI user numbers are published on the DSB’s website. In relation to UPI volumes, UPI generation has increased over the last few weeks, a similar trend seen in advance of the US and EU mandates coming into effect. There are approximately 1.2 million UPIs with over 8,000 new codes generated per week, up from the average of 5,000 per week. Identifier metrics are also published on the DSB website.   

Implementation of the UPI brings to fruition a G20 commitment to improve global oversight of OTC derivatives markets following the financial crisis. Australia and Singapore UPI regulatory reporting comes into effect on 21 October 2024, followed by Japan on 7 April 2025 and Canada on 25 July 2025. Hong Kong has consulted on a start date of 29 September 2025 and further jurisdictions, such as Korea and Saudi Arabia, are also actively preparing to introduce the UPI. 

With the UPI Service still in its inaugural year of live operation, the increasing number of jurisdictions taking such steps for UPI implementation underscores the continued emphasis G20 authorities place on driving OTC derivative regulatory reform.