On 25 July 2025, the CSA Rewrite (Rule 91‑507) officially took effect across all Canadian jurisdictions, establishing a harmonised OTC derivatives reporting regime under the Canadian Securities Administrators’ trade reporting rules
From a Reg‑X perspective, this CSA Rewrite represents a pivotal shift in regulatory reporting standards, aligned with global changes like EMIR Refit and the CFTC Rewrite. Firms now face expanded data requirements, tighter timelines, and elevated expectations for accuracy and governance.
Why the CSA Rewrite Matters
The CSA Rewrite significantly expands the number of reportable data fields, raising them from 72 to 148, covering trade creation, lifecycle events, valuation, collateral, and margin
Other key features include:
- Mandatory Unique Product Identifier (UPI) reporting across all asset classes
- Stricter error‑correction obligations: materially incorrect data must be reported “as soon as practicable” and no later than the next business day
- Expanded daily valuation and margin reporting that now applies more broadly to non‑dealers
- Reporting timelines: dealers remain at T+1, whereas non‑dealers move to T+2 for creation and lifecycle data submission within two business days of execution
The CSA Rewrite further introduces a new, unified Derivatives Data Technical Manual, replacing multiple regional guides and providing consistent standards and examples across jurisdictions
Global Alignment & Harmonisation
The CSA Rewrite is part of a broader global trend toward standardising OTC derivatives trade reporting. It mirrors reforms under EMIR Refit in Europe and the CFTC Rewrite in the US.
Canada has now harmonised cross‑provincial rules and aligned the data taxonomy, including UTI, UPI and other critical data elements, to reduce regulatory burden and improve data quality and consistency
Common Challenges Under the CSA Rewrite
Firms face several regulatory and operational challenges under the new regime:
- Fragmented data collection from administrators, brokers, custodians, internal treasury, and trading systems
- Complex and evolving templates and validation rules across jurisdictions
- Manual workflows and pressured windows for data collection and validation
- Risks of regulator scrutiny where data is incomplete or inaccurate
The CSA Rewrite thus demands rigorous data governance, reliable source integration, and automation to reduce operational risk.
How Reg‑X Supports CSA Rewrite Compliance
At Reg‑X, we have developed solutions tailored to help firms meet the demands of the CSA Rewrite efficiently:
1. Direct Source Integration
We connect directly to fund administrators, brokers, custodians, and internal systems to ensure accurate, timely data sourcing.
2. Automated Workflow & Validation
Our platform automates report generation and builds in validation logic aligned with the CSA Derivatives Data Technical Manual. Errors are flagged promptly and corrected within regulatory timelines.
3. Data Quality Assurance
We enforce accuracy, completeness, and error/omission analytics to ensure quality across all 148 reportable fields.
4. Jurisdiction-Specific XML Submission
Reg‑X supports ETS-compliant XML output for all jurisdictions, Ontario, Québec, Manitoba and the remaining provinces, ensuring seamless submission to trade repositories under OSC Rule 91‑507 and its equivalents
- Operational Reporting & Dashboarding
Our MI dashboards provide self-service visibility and audit‑ready exports, giving compliance and operations teams instant oversight.
6. AI‑Supported Data Insights
We deliver actionable AI-driven insights for remediation, anomaly detection, and ongoing assurances, ensuring governance and accuracy remain central to your reporting strategy.
Key Benefits of Reg‑X for CSA Rewrite Compliance
Benefit | Description |
Regulatory alignment | Full support for CSA Rewrite’s expanded data field requirements, error reporting rules, and UPI mandates |
Operational efficiency | Automated workflows reduce manual effort and accelerate submission timelines |
Data integrity | Rigorous validation aligned to the CSA Derivatives Data Technical Manual |
Assurance & audit readiness | Transparent MI dashboards and audit‑ready exports to support oversight |
Scalability | A framework aligned with global OTC derivatives reporting standards, not just the CSA Rewrite |
Final Thoughts
As the CSA Rewrite takes full effect on 25 July 2025, firms must ensure they meet expanded requirements for accuracy, timeliness, and technical compliance. The regime is non-negotiable: materially incorrect data must be corrected promptly, UPI must be reported across asset classes, and reporting timelines have narrowed.
At Reg‑X, we believe that robust regulatory reporting frameworks should support, not impede, capital markets operations. We help firms embed compliant, resilient, and transparent reporting from day one.
If you are navigating the CSA Rewrite and need to streamline compliance with full jurisdictional coverage and AI-powered assurance, Reg‑X is ready to support your journey.
