HKMA Releases Updated Validation Rules in Response to Common Data Quality Issues
The Hong Kong Monetary Authority (HKMA) and the Hong Kong Trade Repository (HKTR) have released updates to their validation rules, providing further clarification and strengthening reporting expectations under the ISO 20022 regime.
As outlined in the official regulatory circular issued on 5 May 2026, the updated HKTR validation rules will go live on 21 November 2026.
Following its review of early ISO 20022 reporting data submitted since the market transition last year, the HKMA identified a number of recurring reporting errors and data quality deficiencies that limit effective risk monitoring and regulatory transparency. In response, the regulator has introduced a revised validation framework aimed at improving data accuracy, completeness, and consistency across submissions.
The updated rules materially strengthen both mandatory and conditional reporting requirements, with particular emphasis on UPI reporting obligations and enhanced data quality controls.
Updated validation rules effective: 21 November 2026
References:
Announcement:
Summary of Added Rules
| Code | Rule |
|---|---|
| iso-doc-vr-0144 | Expiration date ≥ Effective date |
| iso-doc-vr-0145 | Strike price required for OPTN/SWPT when all barrier levels are blank |
| iso-doc-vr-0146 | Leg 1 fixed-rate day count + payment frequency required when Fixed rate Leg 1 is populated for FRAS/OPTN/SWAP/SWPT |
| iso-doc-vr-0147 | Leg 1 floating-rate day count + payment frequency required when floating-rate ID/indicator/name is populated |
| iso-doc-vr-0148 | Leg 2 fixed-rate day count + payment frequency required when Fixed rate Leg 2 is populated for FRAS/OPTN/SWAP/SWPT |
| iso-doc-vr-0149 | Leg 2 floating-rate day count + payment frequency required when floating-rate ID/indicator/name is populated. Note: attached also has a second version adding floating-rate reference period Leg 2 time period |
| iso-doc-vr-0150 | Price required for CRDT/EQUI/INTR/COMM + CFDS |
| iso-doc-vr-0151 | Price required for EQUI/COMM + FORW |
| iso-doc-vr-0152 | Price required for INTR + FRAS/FORW/OPTN/SWAP/SWPT when rates/spreads/strike/premium are blank |
| iso-doc-vr-0153 | Price required for EQUI/COMM + FRAS/OPTN/SWPT when rates/spreads/strike/premium are blank |
| iso-doc-vr-0154 | Price required for CRDT + FRAS/FORW/OPTN/SWAP/SWPT when rates/spreads/strike/premium blank and Other payment type not UFRO |
| iso-doc-vr-0155 | Price required for EQUI/COMM + SWAP when spreads and strike price are blank |
| iso-doc-vr-0156 | For INTR, Leg 1 must have Fixed rate or floating-rate ID/indicator |
| iso-doc-vr-0157 | For INTR + SWAP/SWPT, Leg 2 must have Fixed rate or floating-rate ID/indicator |
| iso-doc-vr-0158 | Floating rate name Leg 1 required when indicator Leg 1 = OTHR |
| iso-doc-vr-0159 | Floating rate name Leg 2 required when indicator Leg 2 = OTHR |
| iso-doc-vr-0160 | Exchange rate required for CURR + CFDS/FORW/SWAP/SWPT |
| iso-doc-vr-0161 | Exchange rate basis required for CURR + CFDS/FORW/OPTN/SWAP/SWPT |
| iso-doc-vr-0162 | Total notional quantity Leg 1 required for EQUI/COMM |
| iso-doc-vr-0163 | CDS index attachment point < CDS index detachment point |
| iso-doc-vr-0164 | Notional quantity Leg 1 or schedule required for COMM |
| iso-doc-vr-0165 | Notional quantity Leg 1 ≤ Total notional quantity Leg 1 |
| iso-doc-vr-0166 | Notional quantity Leg 2 or schedule required if Total notional quantity Leg 2 is populated |
| iso-doc-vr-0167 | Notional quantity Leg 2 ≤ Total notional quantity Leg 2 |
| iso-doc-vr-0168 | Option type and Option style required for OPTN/SWPT |
How Qomply can help
Qomply’s advanced quality assurance tools and dedicated Hong Kong office provide the technical precision required to navigate the system-level UPI mandates and tightening validation rules introduced in the HKTR’s upcoming November release. By enabling firms to identify data quality gaps and format anomalies before the updated validation rules take effect, we provide the certainty needed to maintain compliance in a shifting APAC market.
Frequently asked questions
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The updated HKTR validation rules are new and revised reporting checks introduced by the Hong Kong Monetary Authority to improve the accuracy, completeness, and consistency of ISO 20022 OTC derivatives reporting. The rules address common data quality issues identified after the market’s transition to ISO 20022 reporting and include stronger mandatory and conditional field requirements.
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The updated HKTR validation rules are expected to take effect in the November 2026 HKTR system release, with the article identifying 21 November 2026 as the effective date. HKTR has also published related technical specification updates, with AIDG ISO 20022 Standard version 1.0.4 updates effective in UAT from 14 September 2026.
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The HKMA introduced the updated validation rules after identifying recurring reporting errors and data quality deficiencies in early ISO 20022 submissions. The enhanced rules are intended to strengthen regulatory transparency, improve risk monitoring, and ensure more reliable OTC derivatives reporting data across Hong Kong reporting entities.
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The new HKTR validation rules focus on data quality controls across fields such as expiration dates, effective dates, strike prices, fixed and floating rate details, exchange rates, notional quantities, option data, CDS attachment and detachment points, and price reporting. They also place particular emphasis on system-level UPI reporting obligations.
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Firms should review their ISO 20022 reporting processes, test against the updated HKTR validation logic, identify missing or inconsistent fields, and resolve UPI, price, notional, rate, and exchange-rate data issues before the November 2026 release. Qomply can support this by helping firms detect data quality gaps, formatting anomalies, and UPI reporting issues before the enhanced controls go live.
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