- Canada's updated derivatives reporting rules, effective July 25, 2025, aim to further align with global standards and improve market transparency and data quality.
- Key aspects of the final regulation changes include the adoption of additional critical data elements, introduction of collateral reporting requirements, updates to the reporting party determination hierarchy, and error reporting for reporting parties.
- Successful implementation relies on early engagement, continuous dialogue, and rigorous testing among industry stakeholders, regulatory bodies, and trade repositories.
Reporting changes for North America, Asia and Europe are occurring simultaneously and do not appear likely to decrease in frequency anytime soon. While multiple changes may cause short term challenges for the industry, these steps toward regulatory alignment, with harmonized global standards, represent significant strides in improving global market transparency and data quality.
The North America derivatives reporting regime has undergone several major regulatory changes in the last few years. This includes the Commodity Futures Trading Commission (CFTC) Rewrite in 2022, CFTC Unique Product Identifier (UPI) adoption for the credit, equity, interest rates and FX asset classes in January 2024, and CFTC Real Time Reporting changes in October 2024.
2025 will see the North America derivatives reporting regime change further with the planned introduction of amended reporting rules in Canada on July 25, 2025. These amended rules are intended to further align Canadian reporting standards with global regulatory standards and include the following important aspects:
- Critical Data Elements and Global Harmonization: The Canadian Securities Administrators (CSA) have included specific Regulatory Oversight Committee (ROC) Critical Data Elements (CDE) to align with global standards and the CFTC adoption of CDEs in 2021. The CSA’s Technical Manual generally aligns with the CFTC Technical Specification and 114 of the 148 fields in the Technical Manual are CDE fields.
- Collateral Reporting Requirements:The amended rules introduce collateral reporting for Canada, which was also introduced by the CFTC in their 2022 rewrite.
- Reporting Hierarchy: Changes in the hierarchy to determine which party must report a transaction through the adoption of the Global Unique Transaction Identifier (UTI) waterfall.
- Errors and Omissions: The amended rules add requirements for trade parties to identify and report errors and omissions as well as make necessary corrections and resubmissions to trade repositories.
The adoption of ISO20022 XML, however, is out of scope for the 2025 Canada Rewrite. The CSA, like the CFTC, has not published its requirements for ISO20022 XML but is expected to publish requirements in the future.
Keys to a Successful Implementation
Critical to the successful implementation of the 2025 Canada amended reporting rules is collaboration between the industry, trade repositories, and regulatory bodies. Engaging with stakeholders early in the process, maintaining open dialogue, and testing the new reporting standards are three crucial factors.
DTCC Data Repository (US) LLC (DDR), a designated or recognized trade repository in each of the thirteen Canadian provinces and territories, is committed to playing a leading role in the transition to the amended reporting rules. DDR is engaged with industry working groups coordinated by the International Swaps and Derivatives Association (ISDA) to understand concerns from market participants, runs a weekly working group with its clients, and participates in ad hoc reviews with other trade repositories to ensure optimal delivery across the industry. DDR also plans to provide clients with ample opportunity test against the amended rules and, thereby, identify and resolve issues in advance of go live. Initial testing began within DDR’s simulator tool on March 14th, and full end-to-end testing is currently planned to follow on April 25th, 2025.
In addition to DDR’s efforts, DTCC’s best-in-class client support teams, deep subject matter expertise, and Trade Reporting Analytics tool uniquely position us to help firms navigate the complexities of the Canada rewrite.
“By fostering industry collaboration, early engagement, continuous dialogue and rigorous testing, the implementation of the 2025 Canada Rewrite changes is expected to be seamless,” said Michele Hillery, DTCC Managing Director, Head of Repository & Derivatives Services. “The industry is sure to see future requirements from regulators, and DDR continues to be prepared for success in the journey for global harmonization of derivatives reporting.”