Canada Rewrite rules are set to commence on 25 July 2025 (Go Live). The intent of the regulatory updates is to harmonise the Canadian regulations with other global trade reporting regimes, to have improved data quality, transparency and standards – this has resulted in major changes being introduced.
In sharp contrast to the other recent global rewrite and refits (EMIR, ASIC, MAS etc), ISO 20022 will not be included in this stage of Canada Rewrite. It is expected to be introduced in a future rewrite for the CFTC and therefore the CSA, around 2026. Therefore, CSV formats are still allowed to be reported, with the XML format expected to be introduced at a later stage.
It is important to note that the Canadian trade reporting regime is separately implemented by each of Canada’s 13 provincial regulators. Collectively, these provincial regulators act as a co-ordinator and in that capacity are known as the ‘Canadian Securities Administrators’ (CSA).
1. Additional and updated data fields:
- Legal Entity Identifier (LEI) – All Canadian market participants need to have LEIs, which must be renewed if they have lapsed or expired.
- Unique Trade Identifier (UTI) – This will replace the Unique Swap Identifier (USI).
- Unique Product Identifier (UPI) – This is required for all asset classes. There has been a delay on the requirement to have a UPI for commodities. The CSA published a Blanket Order in February 2025 which provides an exemption, such that the UPIs for commodities in their current state can continue to be used after Go Live. In Ontario, the Blanket Order will cease to be effective on 24 January 2027. In respect of the other Canadian provinces, the cessation date for the Blanket Order varies and is even uncertain for some provinces. The intention is that there will be coordination amongst the Canadian jurisdictions on the use of commodity UPIs. For more information on UPIs see our article here.
- Other Additional Fields – There will be the introduction of approximately 70 new Common Domain Element (CDE) fields (as endorsed by IOSCO). Note there has been the removal of data elements that relate to excess collateral, which do not align with those elements as required by the CFTC. Derivative dealers are also to report information on valuation, collateral and margin.
2. Alignment across Canadian provinces:
There will be alignment of the ‘local party’ and ‘affiliated entity’ definitions amongst the 13 Canadian provinces.
3. Extended reporting deadline:
This has been extended to T + 2 for reporting counterparties (that are not derivatives dealers, clearing agencies or their affiliates) in relation to data for creation and lifecycle events.
4. Position reporting:
With the intent of enhancing transparency and regulatory oversight, position level reporting has been expanded to include contracts for difference and commodity derivatives.
5. Significant Errors and Omission:
Reporting entities are to notify the Commission as soon as practicable after discovery of the error or omission. In addition, local counterparties that are non-reporting counterparties now will have the onus of verifying that the data from their counterparty is accurate and if not, they are to notify the reporting counterparty of the error or omission.
6. Porting:
The regulations provide a process for porting (i.e. the transferring of reporting from one trade repository to another). For more information on what is involved with porting please see our article here.
If you have any further questions relating to Canadian trade reporting, please see our FAQs here.
How can TRAction assist?
If you need assistance in understanding the Canadian Rewrite regulations and how this may impact your firm, or are experiencing issues with your trade reporting, data quality or issues relating to the root causes as we have described, please get in touch with us.
