Identifiers: LEI, UTI, and UPI

When you prepare the data used to report trade information, you tell the legal entity, the trade, and the product apart with a separate identifier for each, and enter those identifiers in the report data.

What the three identifiers identify

The Legal Entity Identifier (LEI), the Unique Transaction Identifier (UTI), and the Unique Product Identifier (UPI) show, in reports to regulators (see the Regulatory Reporting page), who entered into which trade on which product¹. They are also known as the legal entity, transaction, and product identifiers. An International Organization for Standardization (ISO) standard sets the form of each of the three².

The three have different roles, so none can replace another.

Consider a hypothetical example in which entity X and entity Y enter into two interest rate swaps on the same product, and both are subject to reporting.

Even if the same two entities enter into many trades on the same product, the LEI and the UPI stay the same, and the UTI is what tells those trades apart. In the reported data, the LEI identifies the parties, the UPI the product, and the UTI the individual trade. If X generated the UTI, its first 20 characters are X's LEI.

LEI structure and registration data

Each legal entity gets only one LEI. Once a code is assigned, it is never assigned to another entity, even after the entity ceases to exist. An entity cannot obtain a second LEI either³.

The 20 characters are divided as follows³.

The prefix shows which issuer first issued the LEI (except for LEIs issued before November 30, 2012). The LEI does not change when an entity moves its LEI management to another issuer, so the prefix does not show the current managing issuer³. According to the Q&A of Japan Exchange Group, characters 7 to 18 are random alphanumeric characters⁴.

How LEIs are issued

LEIs are assigned by issuers (Local Operating Units, LOUs) within an international framework, the Global LEI System. The Regulatory Oversight Committee (ROC) oversees the framework. The Global Legal Entity Identifier Foundation (GLEIF), a nonprofit foundation set up in June 2014, handles its operations. GLEIF accredits the issuers under the ROC's oversight⁵. The ROC is also responsible for the international governance of the UTI and the UPI, as well as the LEI⁶.

The flow from application to publication is as follows⁷.

Figure description

The entity applies to an issuer (in some cases through an agent it has explicitly authorized). The issuer collects a minimum set of information, such as name and address, and has the entity confirm it. The issuer then checks it against reliable sources such as public registers, and publishes the LEI and the registration data. Because of this check, it takes time from application to publication.

In Japan, Japan Exchange Group/Tokyo Stock Exchange is an issuer. It asks for documents such as a certificate of registered matters, and says that issuance takes at least 5 business days from application, even at the fastest⁸.

Some issuers serve only a specific country, and others accept entities from anywhere in the world. Languages, bulk registration, and fees also differ by issuer⁷.

Registration data linked to an LEI

An LEI is linked to registration data on "who is who" (the entity's name, location and so on) and "who owns whom" (the ownership structure), which anyone can view in GLEIF's index, the Global LEI Index⁹. The registration data includes the legal name, the addresses of the headquarters and the place of formation, the date the LEI was first assigned, the date of the last update, and the expiry date³.

How the LEI is used in reporting in Japan

In trade information reporting in Japan, the entity responsible for reporting and the counterparties are entered by their LEIs. Even if a branch LEI is registered with GLEIF, the LEI reported is the head office's. A branch LEI issued abroad cannot be reported either¹². The treatment of a counterparty without an LEI is covered on the Regulatory Reporting page.

Japanese financial institutions and business corporations may also need an LEI under the regulations of other countries when they trade in Europe, the United States, and elsewhere¹³.

How UTIs are generated and reassigned

The UTI is a code assigned to each trade subject to reporting. It is used to prevent duplicate reports and to let authorities aggregate data across countries. It has at most 52 characters of uppercase letters and digits, and its first 20 characters are the LEI of the entity that generated it¹⁴.

Who generates it

Who generates the UTI is decided by 13 questions, answered in order for each trade, in the international guidance (the UTI Technical Guidance published in 2017)¹⁵.

The main stages are as follows. The numbers are the order of the stages as regrouped here, not the step numbers in the guidance.

1. If a central counterparty is a party to the trade, the central counterparty generates it.
2. Otherwise, if a party is a clearing member and trades as a clearing member, that clearing member generates it.
3. For a trade executed on a trading platform, the platform generates it.
4. Stages that ask about the circumstances of the trade follow, such as whether the trade spans several jurisdictions and whether both parties have a reporting obligation (steps 4 to 10 of the guidance).
5. If the parties have an agreement on who generates it, that agreement applies. If not, the guidance asks in turn whether an electronic matching platform can generate it, and then whether a single trade repository can.
6. If none of these decides it, the characters of the parties' identifiers are sorted in reverse order, and the party that comes first in that order generates it.

In Japan, for trades between entities that both have a reporting obligation, the trade information reporting follows this flow, and where it cannot, the parties decide by agreement¹⁶. For a trade reported in several countries, the same flow applies in principle. However, when it is difficult to find out how early the other country's reporting deadline is, that question can be skipped and the flow can move on to the agreement stage. Even then, the reporting entity consults the counterparty in advance and respects the generating method the counterparty follows¹⁷.

How it is passed on

In a trade between entities that both have a reporting obligation, both report the same UTI. The party that generates it therefore shares it with the counterparty, in principle at execution, in time for the reporting deadline. The sharing channel is shown by type of trade as follows¹⁸.

When the same UTI stays and when a new one is assigned

When something changes during the life of a trade, whether the same UTI continues or a new one is assigned depends on what changed¹⁹.

A novation, a swap that results from exercising a swaption, and a cleared trade reported by a central counterparty are each linked to the original trade one to one or one to many. For these new trades, the UTI of the original trade is reported as the "Prior UTI". This item does not apply to many-to-one and many-to-many relationships, in which several trades are replaced by other trades, as in compression²⁰.

When a novation replaces the counterparty entirely, the original trade ends and the new trade gets a new UTI. When only part of it is replaced, the original trade continues under the same UTI, and the replaced part is a new trade with a new UTI. When a swaption option is exercised and a swap results, the swap gets a new UTI, and the swaption's UTI is reported as the Prior UTI.

The UPI and product attributes

The UPI is a code that identifies which product a reported OTC derivative is. The international guidance envisages one UPI for each type of product, linked to the set of reference data elements and values that describes the product. The elements and values are held in the UPI reference data library, which a service provider operates²¹.

The service provider is the DSB, which the Financial Stability Board (FSB) designated in May 2019 as the sole provider. The DSB issues UPIs and operates the reference data library²². In Japan's reporting items, the UPI is 12 characters under ISO 4914, and the value determined by the DSB is used²³.

The reference data elements differ by product. In the DSB's example of a single-currency fixed-to-floating interest rate swap, the elements are asset class, instrument type, fixed or floating, notional schedule (whether constant), single or multiple currency, delivery type, notional currency, reference rate, and reference rate term²⁴. Users access UPIs through the DSB's web interface, its API, or file downloads. They can search by UPI code or by element values, and whether a user can create a new UPI depends on the type of user²⁵.

Replacing identifiers and existing trades

Rules cover three situations: reporting a UTI as a provisional value and replacing it, checking the registration status of an LEI, and applying the identifiers to trades that existed before the new reporting items began.

When it takes time for the party that generates a UTI to share it, a reporting entity that is not that party can report with a provisional UTI. It replaces it immediately once the final UTI is assigned. When a trade or matching platform cannot assign a UTI because of a temporary system failure, the parties to the trade report a provisional UTI and replace it with the final UTI afterward²⁶.

For an LEI, a GLEIF search shows the registration status (issued, or pending transfer)⁵.

Linking data across repositories

For OTC derivative trades, the trade repository differs by jurisdiction, and one jurisdiction can have several repositories. The reported information is therefore collected in several repositories. The FSB's feasibility study on aggregation, published in September 2014, concluded that aggregation requires standardizing data elements, including the worldwide introduction of the LEI and the creation of the UTI and the UPI²⁹. If the LEI shows the entity, the UPI the product, and the UTI the trade in a common form, the same entity, the same product, and the same trade can be recognized across repositories.

In Japan, all three are reporting items, and the UPI was added from reports made on April 7, 2025³⁰.

Notes

1. Financial Services Agency, "店頭デリバティブ取引等の規制に関する内閣府令第４条第１項で定める作成・保存・報告事項 ガイドライン" (Guidelines on the items to be prepared, retained, and reported under Article 4, paragraph 1 of the Cabinet Office Order on the regulation of OTC derivatives transactions, our translation) (December 2022; "the Guidelines"), Attachment 2, section 2(2) (page 49 of the PDF). The UPI is in the comparison table of old and new provisions of the Guidelines (November 2023; "the comparison table"), item 107 (page 2 of the PDF) (in Japanese). ↩

2. LEI: Regulatory Oversight Committee (ROC), "Global LEI System", "The LEI", and Japan Exchange Group, "LEIに関するQ&A" (Q&A on the LEI, our translation), A1-1. UTI: the Guidelines, Attachment 2, section 2(2). UPI: the comparison table, item 107, and Financial Stability Board (FSB), "Governance arrangements for the UPI", note 2 (in Japanese except the FSB and ROC documents). ↩

3. Regulatory Oversight Committee, "Global LEI System", "The LEI". The structure of the code (characters 1–4, 5–6, 7–18 and 19–20), the principles of uniqueness and exclusivity, the method for the check digits, the items of registration data, and the "Managing LOU" field. ↩ ↩² ↩³ ↩⁴ ↩⁵

4. Japan Exchange Group, "LEIに関するQ&A" (Q&A on the LEI, our translation), A1-5 (page 1) (in Japanese). ↩

5. Regulatory Oversight Committee, "Global LEI System", "The Global LEI Foundation" (the establishment of GLEIF; the registration statuses "issued" and "pending transfer") and "Local Operating Units" (the accreditation of issuers). ↩ ↩²

6. Financial Services Agency, "コメントの概要及びコメントに対する金融庁の考え方" (Summary of the comments and the Financial Services Agency's responses to them, our translation) (November 21, 2023), "ROC (Regulatory Oversight Committee: the international governance body for the LEI, UTI, UPI and CDE)" (in Japanese). ↩

7. Regulatory Oversight Committee, "Global LEI System", "Local Operating Units". Self-registration, the collection of minimum registration information and its confirmation by the entity, the check against reliable sources, the difference between country-specific and global issuers, and the example of annual certification. ↩ ↩² ↩³

8. Japan Exchange Group, "LEIに関するQ&A" (Q&A on the LEI, our translation), A1-1, A1-2 (page 1) and A2-2 (page 2) (in Japanese). The issuer in Japan is Japan Exchange Group/Tokyo Stock Exchange, which asks for official documents proving the entity exists (such as a certificate of registered matters). ↩

9. Global Legal Entity Identifier Foundation, "Introducing the Legal Entity Identifier (LEI)". The LEI answers "who is who" and "who owns whom", and the Global LEI Index. ↩

10. Japan Exchange Group, "LEIに関するQ&A" (Q&A on the LEI, our translation), A3-1, A3-2 (page 3) (in Japanese). ↩

11. Japan Exchange Group, "LEIに関するQ&A" (Q&A on the LEI, our translation), A2-3 (page 2) (in Japanese). ↩

12. Financial Services Agency, "コメントの概要及びコメントに対する金融庁の考え方" (Summary of the comments and the Financial Services Agency's responses to them) (November 21, 2023), No. 2 (items 7 and 8 of Attachment 1) (in Japanese). ↩

13. Japan Exchange Group, "LEIに関するQ&A" (Q&A on the LEI, our translation), A1-3 (page 1) (in Japanese). ↩

14. The Guidelines, Attachment 2, section 2(2), "What is the Unique Transaction Identifier (UTI)" (page 1; page 49 of the PDF) (in Japanese). ↩

15. The same document, Attachment 2, section 2(2), "(Reference) Flow in the Technical Guidance", steps 1 to 13 (page 2; pages 50–51 of the PDF). Step 4 asks whether the trade spans jurisdictions, step 5 whether both parties have a reporting obligation, step 11 about an agreement, step 12 about the matching platform, and step 13 about a single trade repository and the method of choosing by sorting characters in reverse order (in Japanese). ↩

16. The same document, Attachment 2, section 3(1) (page 3) and 3(2) (page 4); pages 51–52 of the PDF (in Japanese). ↩

17. The same document, Attachment 2, section 3(3) (page 5); page 53 of the PDF (in Japanese). ↩

18. The same document, Attachment 2, section 4(1) (page 5) and 4(2) (page 6); pages 53–54 of the PDF. Sharing is in principle at execution. The table summarizes the approach by product in 4(2), to the extent this table needs. For trades between the central counterparty and each party, the UTI is shared by the central counterparty where necessary (in Japanese). ↩

19. The same document, Attachment 2, section 5(1) (pages 6–7); pages 54–55 of the PDF (in Japanese). ↩

20. The same document, Attachment 2, section 5(1), note 8 (swaptions; page 6) and note 10 (novations; page 7); pages 54–55 of the PDF. That compression and similar cases are outside the item is in the Prior UTI item of Attachment 1 of the same document (page 13 of the PDF) (in Japanese). ↩

21. Financial Stability Board, "Governance arrangements for the UPI" (October 9, 2019), 1.3 "The UPI" (pages 3–4; pages 7–8 of the PDF). ↩

22. The same document, note 2 in the Executive Summary (page 5 of the PDF). The DSB's issuing and operating roles are on page 1 of Derivatives Service Bureau, "The Unique Product Identifier (UPI): How to search for, and create, a UPI via the GUI" (2023; "the DSB guide"). ↩

23. The comparison table of the Guidelines (November 2023), item 107 (page 2 of the PDF). The allowed value is "Char(12)", the remark is "ISO 4914 Unique product identifier", and "determined by the DSB, the UPI issuer" (in Japanese). ↩

24. The DSB guide, Figure 1 on page 1 (an example from the DSB's test environment). The element names follow the source. ↩

25. The same document, page 1 (screen, API, and file download), pages 2–3 (search by UPI code and by attributes) and page 5 (the types of user who can create a UPI). ↩

26. The Guidelines, Attachment 2, section 3(1) (page 3) and 4(1) (page 5); pages 51 and 53 of the PDF (in Japanese). ↩

27. Financial Services Agency, "コメントの概要及びコメントに対する金融庁の考え方" (November 21, 2023), No. 5 (items 43 and 107 of Attachment 1) (in Japanese). ↩

28. The Guidelines, Attachment 2, section 5(2), "Treatment of existing trades" (page 7; page 55 of the PDF) (in Japanese). ↩

29. FSB, "Governance arrangements for the UPI", 1.1 "FSB OTC derivatives data Aggregation Feasibility Study" (page 3; page 7 of the PDF). It quotes the conclusion of the September 2014 study. ↩

30. The comparison table of the Guidelines (November 2023), "固有商品識別子（UPI）及びデルタについて" (On the Unique Product Identifier (UPI) and delta; page 1 of the PDF) and item 107 (page 2 of the PDF). That the UPI was not among the reporting items as of April 1, 2024 is in the note to Attachment 1 (page 2) of the Guidelines (in Japanese). ↩