This report recommends the following, which will be needed irrespective of the particular aggregation model chosen.

  • The work to establish uniform global identifiers, i.e. agreement on a UTI and UPI as well as adoption of the LEI, should be accelerated to ensure that OTC derivatives data can be adequately aggregated. These steps are important under any option for an aggregation mechanism, and indeed more generally to improve the usability of TR data. The work will probably require official sector impetus and coordination as well as partnership with the industry to achieve global acceptance and serve public interest goals.

  • International work should take place, involving a broad range of authorities and TRs, to develop global guidance on harmonisation of data elements that are reported to TRs and are important to aggregation by authorities.

  • The work to develop and implement a global aggregation mechanism should not wait until the global identifiers are in place. If policy-makers decide to develop such a mechanism, that work should be conducted in parallel with the development of identifiers to ensure that the global aggregation of data can be implemented as soon as possible to enable authorities to fulfill their mandates.

  • As part of the work leading to the implementation of the global aggregation mechanism, and before any formal project is launched, the following steps should be urgently undertaken:

    • Study in more detail and address the legal and regulatory changes that would be needed to implement a global aggregation mechanism that would meet the range of authorities’ data access needs;

    • Further consider the appropriate governance structure of an aggregation mechanism;

    • Study further the data and technological requirements for an aggregation mechanism so as to better support a more detailed project specification.

    • Undertake a more detailed assessment of potential costs, beyond the initial discussion of cost drivers provided in this report, based on further analysis of the business requirements and priorities of the authorities and complexity of the use cases.