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Circular to Licensed Corporations - Updates on the implementation of ISO 20022 Standard related to Hong Kong’s Over-the-Counter (OTC) derivatives reporting requirements

May 22, 2025
Latest News SFC Circular to Licensed Corporations - Updates on the implementation of ISO 20022 Standard related to Hong Kong’s Over-the-Counter (OTC) derivatives reporting requirements

On May 21, 2025, the Hong Kong Trade Repository ("HKTR") announced readiness of its system for ISO 20022 standard implementation, one week earlier than the regulatory date. Reporting entities can migrate to ISO 20022 between September 22-28, 2025, to prepare for mandatory implementation on September 29, 2025. The HKTR will run both systems in parallel to support legacy trades. Additionally, the Supervision of Markets Division was established to oversee markets, and the Securities and Futures Commission ("SFC") announced reporting entities can switch to ISO 20022 between specified dates.

This article was generated using SAMS, an AI technology by Timothy Loh LLP.

On May 21, 2025, the Hong Kong Trade Repository ("HKTR") announced the readiness of the HKTR system for the implementation of the ISO 20022 standard, beginning on September 22, 2025, a week earlier than the regulatory implementation date of September 29, 2025. This early system readiness aims to provide reporting entities with a one-week period to prepare for their migration process.

Reporting entities are given the option to transition to the ISO standard from September 22, 2025, and begin reporting trades under the new standard, while the mandatory implementation commences on September 29, 2025. The transitional period for migrating all long-dated legacy trades to the ISO standard remains in place for six months.

Entities reporting trades in the ISO standard during the period from September 22 to September 28, 2025, will be deemed to have reported the trades under the pre-implementation requirements and should refrain from reporting the same trades in the pre-ISO system. Additionally, updates to technical specifications related to Hong Kong’s OTC derivatives reporting and contact information for inquiries were announced.

On May 21, 2025, the Supervision of Markets Division was established to oversee the efficient functioning of markets and protect investors and consumers. Its mandate is to ensure fair competition, transparency, and the integrity of markets.

This division was created to address concerns arising from the growing complexity and interconnectedness of financial markets. It comprises several departments, including Market Surveillance, Compliance, and Enforcement, each contributing to the division's objectives.

The Market Surveillance department utilizes advanced technologies to monitor market activity for suspicious behavior. The Compliance department ensures that market participants adhere to regulations and standards. The Enforcement department imposes penalties and sanctions on violations.

The division collaborates closely with other regulatory bodies to maintain a robust regulatory framework. On the same date, the Securities and Futures Commission ("SFC") announced that reporting entities may switch to the new ISO system anytime between September 22 and September 28, 2025, in preparation for the mandatory implementation on September 29, 2025.

The Hong Kong Trade Repository ("HKTR") will operate both the existing and the new ISO systems in parallel to support short-dated legacy trades and long-dated legacy trades that have not yet been migrated. The definition of long-dated legacy trades includes outstanding trades with an expiry date after September 29, 2026, as outlined in a document published in September 2024.

The page was last updated on May 21, 2025.

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