HKMA Reporting Regulation

What is HKMA Reporting?

HKMA Reporting refers to the requirement put in place by the Hong Kong Monetary Authority (HKMA) and the Securities and Futures Commission (SFC) of Hong Kong for firms to submit details of their derivatives transactions to the HKMA trade repository. HKMA reporting requirements first went live on 10 July 2015, and some adjustments and clarifications have been introduced since then.

The HKMA Rewrite is the latest major update to reporting requirements that were introduced with the aim of improving the accuracy, consistency and timelines of OTC transaction reporting. This aligns it with other reporting jurisdictions such as EMIR, ASIC, MAS, and JFSA, and enhances regulatory oversight.

Who is impacted by the regulation?

The reporting obligation is double-sided, with all of the following firm types are required to report:

Products in scope?

Similar to ASIC, MAS, and JFSA reporting requirements, all OTC derivative trades/positions are in scope for HKMA reporting.

When is the deadline for reporting?

T+2: Reports must be submitted within two business days after the trade is executed.

HKMA Rewrite – summary of changes

The HKMA Reporting Rules have been updated, with the aim of improving the accuracy, consistency and timelines of OTC transaction reporting, aligning it with other major reporting jurisdictions and enhancing regulatory oversight.

1. Compliance Date

  • 29 September 2025

2. Data Standards

  • ISO 20022 XML messaging standard has already been adopted by ESMA, FCA, ASIC, MAS, and JFSA. Adoption of the ISO 20022 messaging standard by HKMA enhances data consistency and interoperability.

3. Unique Identifiers

  • Unique Transaction Identifier (UTI): Global UTI is mandatory for the reporting of all new trades after 29 September 2025. Proprietary UTIs could be used for the reporting of lifecycle events for all legacy positions executed before 29 September 2025
  • Unique Product Identifier (UPI): HKMA has mandated the reporting of UPIs, but this will not be enforced by HKTR system validations from 29 September 2025. The reporting of ISDA Product Taxonomy as a Proprietary UPI will be allowed. LSEG G20 Reporting already supports UPI enrichment via ANNA DSB

4. Party Identifier

HKMA has adopted the following types of identifiers, in the following order of priority:

  • LEI
  • SWIFT BIC code (HKMA specific)
  • Unique Business Identifier by the Company Registry (HKMA specific)
  • Number of the Certificate of Incorporation (HKMA specific)
  • Business Registration Number issued by Inland Revenue of Hong Kong (HKMA Specific)
  • User Defined Code

5. Critical Data Elements (CDEs)

  • Expanded Data Fields: Requirement to report additional critical data elements to improve the granularity and accuracy of reported data.
  • ~176 reporting fields for OTC derivative trades or positions, most of which are in scope for either EMIR, ASIC, MAS, or JFSA; ~28 are HKMA Rewrite-specific 
  • ~34 reporting fields for collateral valuation, all of which are in scope for either EMIR, ASIC, MAS, or JFSA

6. Error Corrections

  • Enhanced Procedures: The use of action type and lifecycle event, together with more detailed guidelines from HKMA to support error correction and the reporting of missing trades

7. Reporting of Valuation and Collateral Valuation

  • Mark to Market or Mark to Model valuations for open positions need to be reported
  • Valuation of collateral posted or received must be reported, for both initial and variation margins

8. Re-Reporting Requirements

Firms have 6 months to re-report legacy positions:

  • Long Dated Positions (remaining maturity of more than 1 year)
    • Re-reporting using ISO 20022XML format
  • Short Dated Positions (remaining maturity of less than 1 year)
    • Lifecycle event – report using pre-ISO or ISO 20022 XML format
    • No lifecycle event – no re-reporting requirement

How can LSEG Post Trade help?

When harnessed, regulation can be powerful. Through years of expertise and trusted data accuracy, Regulatory Reporting can help you reframe regulation, so it’s no longer a hindrance, but an opportunity. To find out we can help you meet your HKMA reporting obligations, visit our G20 Reporting solution page.

Recommended solution

Factsheet

Want to find out more about our products?

Our sales team can provide help and expertise with your product-related queries.

By submitting this form, you agree to your personal data being shared within the London Stock Exchange Group of companies (LSEG) for the purpose of receiving communications via post, phone and electronic means from LSEG about event, resources, products, and/or services.

For more information on how LSEG uses your data, see our Privacy Statement. You can adjust your preferences at any time through the preference link in any electronic communication that you receive from us.

Global Customer support

Regulatory reporting offers a follow the sun support model to our clients. In addition to the proactive monitoring of our regulatory reporting platform, we also provide 24x7 hardware and infrastructure monitoring as standard.

Call our customer support line: +44 (0)20 7797 1122

Disclaimer

Content on this page is not intended as an exhaustive or definitive guide to the regulations, and is not the views of LSEG, but for general information purposes only. For detailed and up to date guidance on regulation you should always seek specialist advice and/or consider the actual regulation itself.