There is a natural convergence towards using Unique Product Identifiers (UPIs) in transaction reporting.
Since this year, UPIs have become mandatory for CFTC transaction reporting in the US. In the UK and EU, UPIs are still considered secondary to ISINs and are used only when an ISIN is unavailable. However, recent consultation responses indicate that the financial industry in the UK and Europe is moving towards the adoption of UPIs for all reporting regimes, including MiFIR.
In April 2024, three notable trade associations (AIMA, GFXD, and ISDA) advocated for the simplification and enhancement of the EU reporting regime through the adoption of UPIs across transaction reporting regimes. They argued for MiFIR to fully adopt UPIs, including RTS2 (trade reporting), RTS22 (transaction reporting), and RTS23 (FIRDs reference data), reflecting a major shift towards harmonizing UPI usage.
Despite being less granular than ISINs, UPIs offer numerous benefits for representing OTC derivatives, as they are currently used in all major non-EU OTC derivatives jurisdictions. The article notes that UPIs "will not proliferate to the significant extent ISINs have, and service provision for a single identifier (rather than two) should create economies for users of these services."
Transitioning from ISINs to UPIs does come with some complexity, especially considering the proliferation of ISINs compared to UPIs.
This is where Qomply UPI Finder can help.
Immediate identification & matching of UPIs minimises manual errors & enhances data integrity.
Reduces time spent on manual data matching & verification, allowing firms to focus on core activities.
Lower operational costs associated with manual processes.
Eliminates the management of financial instrument data for firms; Qomply’s data is always up-to-date & accurate.
Easy-to-use web interface that requires minimal training, facilitating quick adoption by users.
Qomply’s API can handle large data volumes & supports integration with end user systems, making it suitable for firms of all sizes.
Global investment firms must manage UPIs alongside ISINs especially in cases where they have cross-jurisdictional reporting responsibilities. As the industry adopts UPIs in reporting, there will be an increased requirement to translate an ISIN into a UPI – and, in some cases, vice versa.
Quickly locating the UPI counterpart of an ISIN is a requirement or will be a requirement across transaction reporting regimes.
UPI Finder is a free tool that simplifies the process of finding the correct UPI based on a given ISIN, ensuring that firms can meet regulatory requirements with ease.
UPI Finder is easy to use, simply input the data and instantly receive the result. And for those firms wishing to automate the process, Qomply also provides an API which can be implemented into users' own automation framework.
Most importantly, firms can weather any transitionary periods as the industry shifts towards a more widespread adaptation of UPIs in reporting.
MiFID, EMIR, ASIC, SFTR, MAS, CFTC
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Many financial instruments have ISINs that should be used in transaction reporting instead of using the descriptive fields of an Instrument such as Instrument Classification Code and Instrument Full Name.
Use ISIN Quest to query ANNA DSB and FIRDs databases in order to retrieve the reportable ISIN for any given trade date.
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