Canadian (CSA) REWRITE

The CSA REWRITE is aimed at aligning Canada’s derivatives reporting regulations with global standards, particularly those set by the CFTC in the United States and ESMA in the EU.

Driven by the need for improved transparency and data accuracy, the changes add new data fields, identifiers and protocols for error correction that ensure trade data reliability.

This alignment not only facilitates smoother cross-border transactions but also enables regulators to monitor and mitigate market risks more effectively. Ultimately, the update enhances market stability, investor protection and operational efficiency across Canada’s financial sectors.

On 25th July 2025 CSA REWRITE will go live.

The CSA REWRITE will bring Canadian trade reporting more in line with international standards, particularly those of the U.S. (CFTC) and European (ESMA) frameworks.

The revision mandates several critical adjustments that organisations must adhere to or face severe penalties and damage to their reputation.

CSA REWRITE brings the following notable changes:

• Expansion of Reportable Data: The rewrite introduces over 70 new reportable data fields, mostly in line with global Critical Data Elements (CDEs). This aligns Canadian standards with CFTC and ESMA requirements, although some unique distinctions remain among these jurisdictions.

• New Identifiers for Global Alignment:

  • Unique Product Identifier (UPI): Now required for all asset classes, facilitating global identification.

  • Unique Transaction Identifier (UTI): A new generation hierarchy specifies which entity is responsible for UTI assignment, mirroring international practices.

• Updated Reporting and Validation:

  • Firms will need to adjust systems to comply with updated data validation rules, with new business rules for complex structures, collateral, and margin reporting.

  • Position-Level Reporting: Expanded to include derivatives like contracts for difference (CFDs) and commodity derivatives, enhancing transparency and regulatory oversight.

• Transition to ISO 20022 Messaging: Although not mandated immediately, the CSA plans to adopt the ISO 20022 XML messaging format in the future, aligning with CFTC's standards and requiring adjustments from firms for consistent, standardized data submission.

• Error and Correction Protocols: Enhanced rules obligate firms to verify reported data and notify regulators of significant errors. Both reporting and non-reporting counterparties must ensure data accuracy, with tighter timelines for corrections.

• Lifecycle Event Reporting: The rewrite specifies nine action types and eleven event types to cover a broader range of transaction activities, adding detail and precision to event reporting (such as novation, early termination, and transfers) for better regulatory tracking.

These changes aim to improve data quality, streamline cross-border reporting and increase compliance transparency for both the CSA and reporting entities. To prepare and adapt for these regulations by July 2025, financial institutions will need to revise internal systems, data collection and validation processes.

CSA REWRITE Consulation Documents - https://www.securities-administrators.ca/news/canadian-securities-regulators-propose-changes-to-enhance-derivatives-data-reporting/

CSA REWRITE Reporting Final Rules - https://www.osc.ca/en/securities-law/instruments-rules-policies/9/91-507/osc-notice-publication-amendments-osc-rule-91-507-trade-repositories-and-derivatives-data

Ontario Securities Commission - https://www.osc.ca/en/securities-law/instruments-rules-policies/9/91-507

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