The Canadian Securities Administrators (CSA) has published final amendments (the Amendments) that streamline and harmonize over-the-counter (OTC) derivatives data reporting with global standards, which became effective on July 25, 2025.
The Amendments are expected to reduce the complexity of market participants’ reporting systems and decrease ongoing operational and compliance costs while improving the consistency and quality of the data available to regulators and the public.
Included with the Amendments is a harmonized CSA Derivatives Data Technical Manual (the Technical Manual) that provides clarity and consistency regarding the format and values for reporting harmonized data elements. These updated data elements align with international standards developed by the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO).
In addition, the amendments also include:
- Updated requirements for trade repository governance, operations and management of risk to align with international standards;
- Improvements that enhance data accuracy and consistency, such as data validation and verification, similar to other global regulators;
- Greater harmonization within the CSA, including a harmonized threshold in the commodity derivatives exclusion for non- dealers;
- Extended reporting deadlines for end-users;
- Optional position level data reporting for certain types of derivatives; and,
- Changes to reporting for derivatives executed anonymously on trading facilities such as swap execution facilities.
The regulator reminds all Canadian market participants transacting OTC derivatives that they must renew their legal entity identifier (LEI). Any Canadian market participant that has outstanding OTC derivatives and does not renew its LEI is not in compliance with securities law.
The amendments to Trade Repositories and Derivatives Data Reporting and related Companion Policies are available for download from the websites of the participating jurisdictions.
The Technical Manual is published in Manitoba Securities Commission Staff Notice 91-701, Ontario Securities Commission Staff Notice 91-705 , and in the relevant Companion Policy for the remaining jurisdictions.
For more information, please call Barbara Hendrickson at BAX Securities Law (647) 403-4606.
This publication is not intended to constitute legal advice. No one should act on it or refrain from acting on it without consulting with a lawyer. BAX does not warrant or guarantee the accuracy or currency or completeness of the publication. No part of this publication may be reproduced without the prior written permission of BAX Securities Law.
