Since launching its UPI service, the Derivative Service Bureau’s user base has doubled to more than 2000 users across 40 markets. In a brief explainer, DSB Managing Director Emma Kalliomaki speaks to Bob Currie about UPI implementation to date, potential changes to DSB cost-recovery models and providing unique identifiers for digital asset derivatives
The Derivatives Service Bureau (DSB) was appointed by the Financial Stability Board in May 2019 to serve as the sole issuer of Unique Product Identifier (UPI) codes and operator of the UPI reference data library.
The UPI is assigned to the OTC derivatives product and serves as the product identification code for OTC derivatives trade reporting. This enables financial supervisors to evaluate data by OTC derivatives product or by any UPI reference data element, helping them to monitor systemic risk and to meet other aspects of their oversight responsibilities.
The DSB is 60% owned by the Association of National Numbering Agencies (ANNA) – the global organisation whose NNA members are responsible for issuance of the International Securities Identification Number (ISIN), the Financial Instrument Short Name (FISN), and the Classification of Financial Instruments (CFI) code. In line with this remit, ANNA has responsibility for oversight of the issuance of OTC derivatives ISINs.
Since 2015, when European regulators announced that the OTC ISIN would be the preferred identifier for EU regulatory reporting under MiFID II and MiFIR, ANNA has worked with the industry, regulators and with ISO to ensure that the design of the OTC ISIN is consistent and complementary to the UPI and the CFI.
“Regulatory factors are invariably a primary driver for standardisation and, since the global financial crisis, the mandating of derivatives transaction reporting and the keen focus from the financial authorities on reference data quality have been key in pushing adoption of the OTC ISIN and UPI,” says Kalliomaki.
UPI implementation to date
Five jurisdictions went live with the UPI during 2024, with a further five scheduled to adopt the UPI this year.
The 2024 implementations began with the US, as part of the CFTC Rewrite in January, and were followed by implementation in the EU and the UK as part of their EMIR Refit transitions respectively from April and September. In the Asia Pacific, UPI adoption was a requirement under the ASIC Rewrite in Australia and the MAS Rewrite in Singapore in October.
“We moved into User Acceptance Testing (UAT) more than six months prior to the first reporting date, giving firms plenty of time to test and prepare,” says Kalliomaki. To support this adoption, the DSB has introduced a dedicated Client Onboarding and Support Platform (COSP), which has enabled users to connect to test and live environments 6.5 days per week and to complete the UPI subscription form via the online portal.
“Since the UPI is the parent of the OTC ISIN, we were able to pre-populate an initial UPI universe by drawing on the OTC ISIN database,” explains Kalliomaki. Following a recommendation from the DSB’s Technology Advisory Committee, the existing OTC ISIN database was used to seed the UPI database by pre-populating OTC ISINs with their UPI parent. This exercise completed more than one month before the first regulatory mandate, removing the need for a large number of UPI create requests from industry at initial release and simplifying operational activities in the first few months that the UPI was live.
When firms have completed this integration of UPI data, this is then available for every jurisdiction. So, firms with multijurisdictional activities should be largely UPI-ready for markets implementing in late 2025 or 2026.
However, there have been some jurisdiction-specific requirements. Japan went live with the UPI in April 2025 and South Korea will be introducing the UPI at the end of the year. This has required some translation of documentation, with the user guide and the UPI onboarding guide needing to be translated into local language.
“The UPI and the OTC ISIN are jurisdiction agnostic, so when we encounter new products and use cases that are location specific, dedicated subject matter experts within the DSB Product Committee evaluate how best to support these products from an identifier perspective,” says Kalliomaki. The market authorities and trade association have been heavily involved in this preparatory dialogue – and in supporting industry education and onboarding through webinars and training guides.
The volume of UPI issuance has remained broadly consistent over the past 12 months, with between 5000 and 7000 identifiers being assigned each week. “While, in advance, we expected a high volume of UPI issuance initially that would reduce slightly over time, in practice this UPI issuance volume has remained consistent with a continuous assignment of UPIs required to cover the release of new products,” says Kalliomaki. Equities have represented the largest asset class for new UPI issuance, followed by rates products.
Cost-recovery and 2026 delivery
In April, the DSB launched its annual consultation, seeking feedback from users regarding its delivery of services during 2026, pricing model and governance.
As an industry utility, DSB operates on a cost recovery basis. In developing the UPI service, the DSB pledged that it would revisit its cost structure for this service within two years of going live. The organisation notes that, following the inception of this UPI service, its userbase has grown to close to 500 fee-paying users and 2000 that access its service free of charge across 40 markets.
“We have canvassed our members to assess whether there is a need to rebalance the cost structure,” says Kalliomaki. From the consultation responses, the industry supported a number of changes to cost allocation across the user base. The DSB will introduce a new fee-paying distributor user type for firms that distribute free DSB data to their end users.
The DSB has also asked for feedback on plans to broaden the intermediary model. Intermediaries provide services to end users, accessing DSB services and distributing this data such that the end user does not need to connect directly to the DSB service. Respondents to the consultation indicated broad support to extend the intermediary model to include all fee-paying DSB users.
“We have already started introducing the distributor user type into DSB contractual agreements and documentation,” says Kalliomaki. An immediate priority is to gather a more detailed profile of the distributor community operating using UPI and OTC ISIN data and this information-gathering exercise will inform any future refinements to its cost structures.
For the next year, DSB plans to introduce a flat fee across both the UPI and OTC ISIN services. “We will evaluate any future plans to move to volume-based or tiered pricing, or any alternative pricing model, when we have greater clarity around how many distributors are currently using DSB data and their usage levels,” she says,
Changes introduced on the basis of the April consultation paper will come into effect on 1 January 2026, with the DSB continuing to consult on some elements of these provisions through a consultation window that will remain open until 27 August. When that is completed, final versions of the legal documentation will be published in September.
Digital asset identifiers
ANNA has been working to support digital asset identification and classification for a number of years, establishing a task force in 2019 to evaluate how it should position itself to service this expansion. This includes issuance of ISO-standard ISINs for digital assets, including the XT ISIN set.
As part of this initiative, ANNA has been working with the Digital Token Identifier Foundation, the ISO-registration authority for the digital token identifier (DTI), which can be used as the identifier for the underlying asset in a digital asset derivative product.
Cryptoasset names are not standardised or unique across trading exchanges and, consequently, it is important that trade reporting and product documentation applies a global standard identifier, such as the DTI, to provide clear and unambiguous identification of the digital instrument.
The DTI uniquely links a cryptoasset with its respective DLT network. A cryptocurrency that is not a jurisdiction-specific asset will typically have an XT-prefixed ISIN with a DTI embedded in it to support that alignment and cross-referencing. Both websites, ANNA and DTI, provide the opportunity to look up the ISIN for a specific DTI, and vice versa.
Within its commodity reference pricing, DSB has approximately 100 DTIs representing underliers that are currently being used to assign UPIs and OTC ISINs.
“We have a feedback loop through the DSB’s Digital Asset Strategy subcommittee to the ISO CFI classification to look at the classification of DTIs and digital assets more broadly,” she says. “The world of digital assets is being aligned and integrated with traditional capital markets. At DSB, and at ANNA more widely, we need to accommodate that as part of our future strategy.”
