Under the ASIC transaction reporting requirements, reporting entities must submit a significantly expanded set of data fields following the rewrite. One field that generates confusion in practice is Item 49: Price Unit of Measure.
TRAction explains:
- what that field means,
- how it connects to the Price field, and
- the common issues that arise when populating it.
What is the “Price Unit of Measure”?
The Price Unit of Measure is a companion data element to Item 47 (Price). Its purpose is straightforward: it tells the regulator what unit the price figure refers to.
The allowable values for this field are drawn from the ISO 20022 external code set ExternalUnitOfMeasure1Code. This is an internationally standardised list of codes that can describe a wide variety of measurement units, from physical commodity quantities (e.g. barrels) to financial or abstract units (e.g. percentage, basis points, a pure number).
The Price Unit of Measure is only required when Price (Item 47) is reported as a monetary amount. Where Price is instead reported as a decimal, the unit of measure is not populated because in that case the units of the price are taken to be the same as the units of Notional amount—Leg 1, making a separate unit field redundant.
This distinction matters in practice. A price expressed as a monetary amount (e.g. AUD 85.50 per barrel) requires the accompanying unit code (e.g. BARL) to give it meaning. A price expressed as a decimal (e.g. 0.0257, representing a rate or ratio) inherits its unit context from the notional, so no separate code is needed.
Importantly, the Rules also establish a clear alignment requirement: for most OTC derivatives where Price is reported as a monetary amount (other than CFDs and forwards over debt instruments), Price Unit of Measure must be reported using the same code as Quantity Unit of Measure—Leg 1. Under the Rules, Notional amount—Leg 1 is calculated as the product of Price and Total notional quantity—Leg 1. For that equation to hold, price and quantity must be expressed in the same units. A mismatch between the two unit codes therefore signals that the reported price, quantity and notional are internally inconsistent.
When there is a price – what is the actual unit?
The right unit of measure depends on both the underlying asset and its class.
FX and Interest Rate Derivatives
For most FX and interest rate derivatives, items such as exchange rate, fixed rate, strike price or spread, serve as the price of the transaction. Where a price equivalent is reported as a monetary amount, the Price Unit of Measure field should match the Quantity Unit of Measure — Leg 1. Where it is expressed as a decimal, the units are taken to be the same as Notional Amount — Leg 1 and the field does not require population.
Equity Derivatives
For equity derivatives such as single-stock CFDs, where price is reported as a monetary amount per share, Price Unit of Measure must match the Quantity Unit of Measure — Leg 1.
Common codes include:
- SHAS (shares) for single-stock products and
- LOTS (lots) where the underlying is quoted in lot sizes (see the Table below for examples).
For Equity Index CFDs, price is more commonly expressed as a decimal (index points), meaning the unit of measure field would not be populated.
Commodity Derivatives
Commodity derivatives are typically priced as a monetary amount per physical unit (e.g. AUD per barrel, USD per metric tonne), which means the price is reported as a monetary amount and the unit code must be populated. The range of applicable codes is wide:
- BARL — barrel
- MTON — metric tonne
- MMBTU — one million British thermal units
- KWHY — kilowatt-hour
- TOCD — tonne of CO₂ equivalent (relevant for carbon derivatives)
- KILO — kilogram
Selecting the wrong code will produce a price figure that is technically present but effectively meaningless for any regulatory analysis or aggregation.
Debt Instruments
For CFDs and other forwards over debt securities or options, where Price is reported as a monetary amount, ASIC’s Technical Guidance identifies ACCY (Amount of Currency) as the appropriate ExternalUnitOfMeasure1Code. This reflects the fact that debt instrument prices are expressed in currency terms rather than physical quantity units, and ACCY is the fit-for-purpose code for that context.
Examples of how the “Price Unit of Measure” is reported for different assets
Example 1: Consider a CFD where the underlying is crude oil, priced at USD 100.10 per barrel. Because the price is expressed as a monetary amount per barrel, Price Unit of Measure is reported as BARL. The same code must appear in Quantity Unit of Measure—Leg 1, so that Price × Total notional quantity—Leg 1 produces a coherent notional amount.
| assetclass | contracttype | PriceUnitOfMeasure | price |
|---|---|---|---|
| COMM | CFDS | BARL | 100.1011 |
Example 2: Gold is treated as a commodity derivative. Where the price is expressed as a monetary amount per troy ounce (for example, USD 4,384.69), Price Unit of Measure is reported as OZTR (TroyOunces).
| assetclass | contracttype | PriceUnitOfMeasure | price |
|---|---|---|---|
| COMM | CFDS | OZTR | 4384.69 |
Example 3: For a CFD over Vodafone shares, price represents the monetary amount per share (for example, GBP 4,414.48 per share). Price Unit of Measure is reported as SHAS (shares), matching Quantity Unit of Measure—Leg 1.
| assetclass | contracttype | PriceUnitOfMeasure | price |
|---|---|---|---|
| EQUI | CFDS | SHAS | 4414.48 |
Example 4: Consider a forward contract over a 5-year UK Gilt, where the agreed purchase price is GBP 0.24107. Because the price is expressed as a monetary amount, Price Unit of Measure must be reported. ASIC’s Technical Guidance is explicit that for forwards and CFDs over debt securities, the appropriate code is ACCY (Amount of Currency).
| assetclass | contracttype | PriceUnitOfMeasure | price |
|---|---|---|---|
| EQUI | CFDS | SHAS | 4414.48 |
Example 5: A CFD on Bitcoin is treated as a commodity derivative. The price (for example, USD 0.00231) is expressed as a monetary amount, so Price Unit of Measure must be reported. The appropriate code here is ACCY.
| assetclass | contracttype | PriceUnitOfMeasure | price |
|---|---|---|---|
| EQUI | CFDS | SHAS | 4414.48 |
What are the issues that arise?
Despite its apparent simplicity, this field is easy to misinterpret. The field label “Price Unit of Measure” can be read literally as the unit of measure in which Price is reported (i.e. the currency amount), rather than what the price itself refers to. That subtle difference in reading is enough to cause reporting errors in practice. The main issues are as follows:
(a) Choosing the Wrong Code – The ISO 20022 ExternalUnitOfMeasure1Code list is extensive, and similar-sounding units can mean very different things. Without a clear understanding of how the underlying market actually prices the commodity, it is easy to select the wrong code.
(b) Populating the Field When It Shouldn’t Be – A common error is populating Price Unit of Measure when Price has been reported as a decimal rather than a monetary amount.
(c) Misalignment with Quantity Unit of Measure—Leg 1 – Because Notional amount—Leg 1 is the product of Price and Total notional quantity—Leg 1, the two unit codes must match. Firms that map these fields from different source systems risk this kind of internal inconsistency.
(d) Counterparty Inconsistency – Each counterparty’s Price unit of measure must be consistent with the other’s. If one counterparty reports BARL and the other reports MTON for the same trade, the reports will never reconcile.
How can TRAction assist?
Price unit of measure is one of many fields where the technical detail matters and the margin for error is narrow. ASIC is actively reviewing submissions, is prepared to require back-reporting, and expects firms to conduct their own breach assessments.
If you need assistance navigating the requirements for this field, or with any aspect of your trade reporting obligations, contact us.
