Regulatory Reforms & Impact on Trade Repostory Usage | DTCC
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This article was originally published by Futures & Options World (FOW) on April 14, 2026.

Michele Hillery, managing director, head of repository & derivatives services, DTCC, observes that over the past few years, regulators in Hong Kong, Japan and Australia have implemented significant rewrites of derivatives trade reporting rules.

These are aimed at improving data quality, harmonising reporting standards and aligning more closely with global Committee on Payments and Market Infrastructure International Organization of Securities Commissions recommendations.

While each jurisdiction operates under its own regulatory framework, these reforms share common features, including expanded data requirements, mandatory use of global identifiers such as unique transaction identifiers and unique product identifiers, and adoption of ISO 20022 reporting standards.

"Collectively, these changes have required firms to review and upgrade their trade reporting processes and systems, increasing the need for robust testing, implementation readiness and ongoing reporting support," said Hillery. "However, the impact on demand for trade repository services has not been uniform across markets."

The clearest example of a measurable increase in demand has been in Japan. Regulatory reforms there mandated the use of the licensed trade repository (DDRJ), replacing a regime where firms were previously permitted to report directly to the regulator.

"This explicit change in the reporting model resulted in a clear increase in repository usage, onboarding activity and ongoing reporting volumes," said Hillery.

Elsewhere, the impact has been driven more by increased complexity and higher data quality expectations, rather than a structural shift toward greater reliance on trade repositories.

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In Hong Kong, recent regulatory changes did not mandate increased use of trade repositories. However, higher technical complexity — particularly around lifecycle reporting and validation requirements — has led some firms to reassess their operating models.

"For certain participants, this has translated into increased engagement with trade reporting service providers to manage complexity and reduce operational risk, although overall demand growth has been incremental rather than structural," said Hillery.

In Australia, the end of post rewrite transitional relief and the expiry of safe harbour provisions — which clarified that legal responsibility for reporting accuracy now sits with the reporting entity, even where reporting is delegated — have driven an increase in direct reporting activity.

"This has been particularly evident among firms bringing previously delegated or simplified reporting arrangements in house," said Hillery. "While this has not fundamentally changed the role of trade repositories, it has contributed to higher reporting volumes and increased implementation effort for some market participants."

Looking ahead for the rest of 2026, a number of APAC jurisdictions are planning targeted enhancements to existing reporting frameworks.

"These include adjustments to reporting logic, refinements to margin reporting, and the introduction of additional data fields designed to make lifecycle reporting more practical and less operationally burdensome for firms," said Hillery. "While these changes may appear incremental individually, collectively they add to the complexity firms need to manage."

Beyond individual jurisdictions, APAC regulators are also closely monitoring developments in other major markets, particularly in Europe.

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"Potential changes emerging from Europe may have downstream implications for APAC jurisdictions as regulators seek to balance local supervisory needs with global alignment," said Hillery. "This ongoing evolution reinforces the importance of scalable and flexible trade reporting solutions."

Together with clients, DTCC has been focused on providing tooling and advisory services to help firms manage the complexity and expertise required to meet these standards.

"Our growing capability around data analytics is a reflection of this demand, and we are developing tooling that helps firms not only detect and triage possible reporting issues but benchmark their performance against their peers," said Hillery. "We believe that this capability also provides an excellent opportunity to use DTCC’s AI framework to explore the way AI can add value, efficiency and risk reduction to trade reporting capabilities."

DTCC continues to invest in technology, particularly cloud based infrastructure through working with partners such as AWS and Snowflake to further improve data handling, processing and scalability.

"One key advantage of this approach – already delivering results – is the ability to run multiple test environments supporting more controlled and efficient industry testing," said Hillery. "Building on this, we are working closely with the industry to further expand our use of cloud services to deliver more efficient methods of data share, a key capability that we expect to deliver significant value in the future."

DTCC has committed to providing a Markets in Financial Instruments Directive (MiFID) approved reporting mechanism service in both EU and UK European Market Infrastructure Regulation (EMIR).

"We believe the evolution of our platform, the high potential for change in MiFID requirements in the future, and the importance of scalable efficiency to Industry make this the right time to expand into MiFID, while also looking at where else we can meaningfully add value and reduce risk," said Hillery.

Michele Hillery
Michele Hillery

DTCC Managing Director, Head of repository & Derivatives Services

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