The derivatives trade repository system is a foundational system established by the Futures and Derivatives Law (the “FDL”). Article 36 of the FDL provides that the relevant departments under the State Council shall establish a derivatives trade repository system to centrally collect, preserve, analyze and manage information on the underlying assets, scale and counterparties of derivatives transactions, and to disclose relevant information to the market in a timely manner according to rules and regulations. Recently, the National Association of Financial Market Institutional Investors (NAFMII) issued the OTC Derivatives Transaction Data Reporting Specifications (Trial Version, July 2026) (the “Specifications”) and the Circular on Matters Concerning OTC Derivatives Trade Reporting (NAFMII [2026] No. 115) (the “Circular”). The Circular requires market participants in the China interbank market (“Interbank Market Participants”) to report information on derivatives transactions concluded outside the trading platforms recognized by the People’s Bank of China (PBOC). This marks the first time that a derivatives trade repository system has been established in China in accordance with the FDL.
I. Scope of Application
According to the Circular, Interbank Market Participants shall report information on OTC derivatives transactions concluded outside trading platforms recognized by the PBOC to both the NAFMII and the Interbank Market Data Reporting Repository (Shanghai) Co., Ltd. (the “Data Repository”).
(1) Underlying assets. The OTC derivatives transactions referred to in the Circular are the trading of swap contracts, forward contracts, non-standardized option contracts and their combinations, other than trading of listed futures or options. This definition is consistent with that of derivatives transactions as defined in the FDL. On that basis, however, the Circular lists several underlying assets of the OTC derivatives transactions to clarify the scope of the reporting obligations, namely: (a) OTC derivatives transactions linked to domestic or foreign interest rates, exchange rates, bonds, credit, gold or their indices or combinations; and (b) OTC derivatives transactions conducted by financial institutions with their clients (including non-financial enterprises) that share the same product structure as those listed above.
In terms of the underlying assets linked to derivatives transactions, the categories listed in the Circular (i.e., domestic or foreign interest rates, exchange rates, bonds, credit, gold or their indices or combinations), shall undoubtedly fall within the reporting scope. According to our verbal consultation with the NAFMII, as specified in the Specifications, at this stage, only OTC derivatives transactions linked to the aforementioned underlying assets, rather than other underlying assets, are required to report their transaction details and position information. However, we note that, although the disclosure of transaction details and position information is limited to the derivatives linked to the above underlying assets, the aggregate statistical information on OTC and exchange-traded derivatives required to be reported under the Specifications is not confined to interest rate-type, exchange rate-type, credit-type, bond-type and precious metal-type underlying assets, but also covers the commodity-type, equity-type, index-type and other underlying assets, that is, the reporting scope has extended beyond the interbank market varieties to include equity-type and commodity-type assets. This broader scope appears to align with the phrase “including but not limited to” used in the Circular to define the reporting scope, suggesting that the range of underlying assets subject to reporting is not limited to those explicitly listed.
Article 8 of the FDL provides that derivatives markets shall be subject to administration and supervision by the futures regulatory authority under the State Council (i.e., the CSRC) or other departments authorized by the State Council, each acting within its respective division of responsibilities. Whether derivatives transactions linked to equities, equity indices, other equity-type securities, stock index futures or commodity futures, commodities and commodity indices, or any combination of the foregoing, will be included in the reporting scope of transaction details or position information as set forth in the Specifications remains to be seen.
(2) Venues of transactions. According to our verbal consultation with the NAFMII, at this stage, the trading platforms recognized by the PBOC are the China Foreign Exchange Trade System (CFETS) and the Shanghai Gold Exchange (SGE). The reporting obligation applies irrespective of whether a derivatives transaction is concluded on a trading platform or venue. Accordingly, derivatives transactions concluded outside the CFETS and the SGE shall fall within the reporting scope, regardless of whether they are concluded on a trading platform or venue.
(3) Reporting entity. The entities subject to the reporting obligations are Interbank Market Participants, i.e., institutions that conduct proprietary trading or asset management business in the interbank markets such as the China Interbank Bond Market (CIBM), interbank foreign exchange market and gold market, which include but are not limited to, commercial banks, securities companies, insurance companies, fund management companies, trust companies, futures companies, their subsidiaries that engage in asset management, finance companies and private fund managers. Asset managers shall bear the reporting obligations for the products they manage.
(4) Overseas participants. The Circular provides that the reporting obligations apply to overseas Interbank Market Participants as well and stipulates that overseas Interbank Market Participants may entrust their settlement agents or custodian banks to submit reports on their behalf. We understand that even if the reporting is delegated to a third party, the Interbank Market Participant itself remains the entity subject to the reporting obligations.
Currently, overseas Interbank Market Participants include: 1) Overseas central-bank-type institutions such as central banks or monetary authorities, international financial organizations and sovereign wealth funds; 2) Overseas institutional investors such as commercial banks, insurance companies, securities companies, fund management companies, futures companies, trust companies and other asset management institutions legally incorporated outside the PRC as well as medium- and long-term institutional investors such as pension funds, charity funds and endowment funds.
Specifically, overseas investors accessing the CIBM via the CIBM Direct scheme, Hong Kong Bond Connect (Northbound), or Qualified Foreign Institutional Investors (QFIIs) and Renminbi Qualified Foreign Institutional Investors (RQFIIs) channels and having completed the filing with the PBOC Shanghai Head Office for the access will all fall within the scope of reporting entities.
These overseas Interbank Market Participants are also required to establish internal trade reporting mechanisms and to file reports in a timely manner.
II. Scope of Reporting
According to the Specifications, the OTC derivatives transaction information to be reported includes the transaction details and position information regarding the OTC derivatives transactions conducted by Interbank Market Participants, as well as the aggregate statistical information regarding their exchange-traded and OTC derivatives transactions.
The transaction details primarily cover the following: the information of both parties, transaction codes, transaction purposes (e.g., hedging, agency trading, market-making and proprietary trading) and directions, business information (including business type, product type and underlying assets), master agreement types (e.g., ISDA, NAFMII, SAC), margin information, notional amounts and prices, transaction execution and maturity dates, delivery, settlement and clearing arrangements. The position information applies to outstanding transactions and includes further details such as the remaining notional amounts, margin utilization and contract valuations (in addition to the above basic information).
Aggregate statistical information on exchange-traded and OTC derivatives transactions is categorized by product types (e.g., interest rates, bonds, credit, exchange rates, commodities, equities, indices and precious metals), and by business types (e.g., options, futures, forwards, swaps and hybrid products), covering: 1) the notional principal, risk exposure and market value of each type of product; 2) margin amounts categorized by counterparty types (e.g., onshore banking financial institutions, onshore non-banking financial institutions, offshore financial institutions, corporate clients and individual clients); and 3) the remaining maturity structure categorized by tenor buckets.
Where the above transaction information has already been reported to interbank market infrastructures or the NAFMII in a systematic and structured manner, Interbank Market Participants may authorize such interbank market infrastructures or the NAFMII to report such information on their behalf.
III. Reporting Frequency
Interbank Market Participants shall report the transaction information of the preceding month to both the NAFMII and the Data Repository within the first five working days of each month. For the initial filing, all historical transaction information from January 1, 2023, onward shall be reported. Based on the effective date of the Circular, the initial filing shall be completed via email by the end of August 7, with the content covering all historical transaction information from January 1, 2023, onward. With only a few days left before the initial filing deadline, the preparation timeline for overseas Interbank Market Participants is very tight.
The Circular further requires that upon the launch of the API service by the Data Repository, Interbank Market Participants shall submit transaction information through the API and adjust the reporting content, frequency and other matters in accordance with the requirements of the Data Repository. According to media reports, although the Circular currently requires monthly reporting, the reporting frequency may be increased to a daily basis once the system is further upgraded by year-end, which would make near-real-time reporting possible.
IV. Compliance Requirements
The Circular requires Interbank Market Participants to establish comprehensive trade reporting mechanisms to ensure the truthfulness, accuracy and completeness of reported transaction information, and to designate dedicated personnel to be responsible for trade reporting related matters. If an Interbank Market Participant is unable to complete the trade reporting on schedule or needs to amend the transaction information already reported, it shall contact the NAFMII and the Data Repository promptly.
V. Inspections and Penalties
The NAFMII has the authority to inspect or investigate Interbank Market Participants’ transaction information reporting practices. The NAFMII may, depending on the severity of the circumstances, impose self-regulatory measures or disciplinary sanctions on incomplete, omitted, inaccurate reporting or other violations.
Our Suggestions
Both domestic and overseas Interbank Market Participants are advised to promptly establish trade reporting mechanisms in accordance with the Circular and complete the reporting in a timely manner. To ensure the timely and comprehensive fulfillment of their compliance obligations, overseas Interbank Market Participants are advised to entrust their settlement agents or custodian banks to submit the reports on their behalf as soon as possible.
Prior to the introduction of this trade repository system, China had already established several reporting mechanisms:
- In the securities and futures markets, the China Securities Inter‑institutional Quote System (CSIS) is primarily responsible for collecting information on OTC derivatives business conducted by securities companies, covering derivatives instrument types such as options and swaps, with underlying assets including but not limited to stocks, stock indices and commodities; China Futures Market Monitoring Center (CFMMC) is primarily responsible for collecting OTC derivatives transaction information from futures risk management subsidiaries registered with the China Futures Association (CFA);
- In the interbank market, the China Foreign Exchange Trade System (CFETS) and the NAFMII have operated as quasi-trade repositories, with the CFETS responsible for OTC derivatives data reporting relating to credit, foreign exchange and interest rates, and the NAFMII responsible for OTC derivatives data reporting relating to credit.
By centrally collecting information on OTC derivatives transactions and positions through the Data Repository, the regulators’ ability to conduct see-through monitoring of financial markets will be enhanced, and critical data support will be provided for macro-prudential management and financial market regulation.
Whether the reporting scope of interbank OTC derivatives trade repository mechanism established under the Circular will lead to overlapping regulatory coverage over equities, equity indices, other equity-type securities, stock index futures or commodity futures that currently fall under the CSRC’s regulation, and how it will coordinate with the CSRC’s trade repository mechanism in the future, remains to be seen.
In addition, whether the derivatives transactions executed between overseas Interbank Market Participants and their offshore counterparties are subject to reporting, and if so, to what level of granularity the derivatives transaction information shall be submitted, remains to be further clarified by the NAFMII.
