Singapore (MAS)

Singaporean Trade Reporting Requirements

The Monetary Authority of Singapore (“MAS”) requires parties to a Specified Derivative Contract (SDC) to report to a licensed trade repository or licensed foreign trade repository.

What type of derivative contracts are reportable?

ONLY over-the-counter (OTC) derivative contracts are reportable under the MAS regime. Exchange-traded derivatives contracts, including futures contracts and block futures contracts, are not in the scope of the regime and therefore don’t need to be reported.

Which are the OTC SDCs?

As defined in section 5 of the Regulations, the following OTC derivatives are required to be reported when traded or booked in Singapore:

From 1 October 2019

  • Interest rate OTC derivative contracts
  • Credit OTC derivative contracts

From 1 October 2021 (postponed for 1 year from 1 October 2020 due to Covid-19)

  • Foreign Exchange OTC derivative contracts
  • Commodity OTC derivative contracts
  • Equity OTC derivative contracts

Exclusions

All the above 5 types of OTC derivatives contracts have the following common exclusions respectively:

  • a debenture;
  • an exchange-traded derivatives contract (ETD); and
  • a unit in a collective investment scheme (CIS unit).

Particularly, foreign exchange derivatives also does not include:

  • forward contract with physical delivery of the currency; or
  • forward contract for sale or purchase of a currency which is intended to be settled by physical delivery of the currency or for settling a sale or purchase of securities denominated in that currency. 

Please refer to section 2 of the Regulations for detailed definitions of these 5 derivatives.

Who is required to report?

Under Section 124 of the Act and Section 6 of the Regulations, the following entities are required to report:

  • any bank in Singapore licensed under the Banking Act (Chapter 19);
  • any subsidiary of a bank incorporated in Singapore subject to exemption;
  • any merchant bank approved as a financial institution under the Monetary Authority of Singapore Act;
  • any finance company licensed under the Finance Companies Act;
  • any insurer licensed under the Insurance Act subject to exemption;
  • any holder of a capital markets services licence (CMSL) subject to exemption; and
  • any significant derivatives holder (SDH) as set out in section 6 of the Regulations.

Who are Significant derivatives holders?

  • The person does not fall into any category above;
  • The person is a resident in Singapore; and
  • The person’s aggregate gross notional amount of SDCs which are traded in Singapore for the year exceeds SGD 8 billion.

Who is exempted from Trade Reporting Obligations?

The Regulations provide some exemptions for the following entities from the reporting obligations:

  • an approved trustee mentioned in section 289 of the Act
  • a licensed trust company that entered into the SDC as a trustee
  • a subsidiary of a bank incorporated in Singapore:
    • which has carried on its business or operations for less than 4 consecutive quarters; or
    • if the threshold of SGD 5 billion for the aggregated gross notional amount is met.
  • a licensed insurer:
    • which has carried on its business or operations for less than 4 consecutive quarters; or
    • if the threshold of SGD 5 billion for the aggregated gross notional amount is met.
  • a CMSL:
    • which has carried on its business or operations for less than 4 consecutive quarters;
    • if the threshold of SGD 5 billion for the aggregated gross notional amount is met; or
    • the counterparty to the relevant SDC is not an accredited investor or an institutional investor (i.e. retail investors).
    • persons specified in the Regulation, including the Singapore government, central banks, multilateral development agencies and international organisations. See the full list in the Fourth Schedule.

    What is the SGD 5 billion threshold?
    This threshold is only applicable if the counterparty to the relevant SDCs is an accredited investor or institutional investor (i.e. not a retail investor). The CMSL holder’s aggregate gross notional amount of the SDCs to which it is a party or which it executes or causes to be executed as an agent of a party to the contract for the year ending on the last day of a quarter, does not exceed SGD 5 billion for:

    • the most recent completed quarter; and
    • each of the 3 consecutive quarters immediately preceding that quarter.

What Information needs to be reported?

The reporting entities are required to report the trade information described below within two (2) business days (T+2).

Depending on the class of SDCs, the reporting details required are different. The following are the reporting information fields required for all classes of SDCs:

  • Contract information such as Unique Transaction Identifier (UTI);
  • Counterparty information such as Legal Entity Identifier (LEI);
  • Clearing information;
  • Contract Confirmation;
  • Trade execution
  • Transactional data;
  • Timestamp information;
  • Option data, if applicable.

Where can I find the MAS reporting rules?

The reporting obligations are set out in Securities and Futures Act (Chapter 289) (“the Act”) and Securities and Futures Act (Chapter 289) and Securities and Futures (Reporting of Derivatives Contracts) Regulations 2013 (“the Regulations”).

If you would like to discuss how the MAS reporting requirements affect you and how you can benefit from our delegated reporting services, please contact us.


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