JFSA Rewrite go-live – an important milestone

As the first in the region, our Japan team achieved a significant milestone with the successful launch of the rewrite on April 1st. Kudos to the industry, our customers, and our partners, who all played a big role in helping to achieve a remarkable 99.85% acceptance rate in the first week. Much of the success can be attributed to our customers, who took ownership and participated actively during the UAT period to validate the test cases.

MAS has published its latest revised OTCD reporting guidelines and FAQs on its website, as well as informing regulated entities of the final reporting regulations. Customers who are in-scope for MAS and ASIC derivatives reporting have shifted to fifth gear in preparation for the October go-live. Our team has also participated in industry webinars and customer forums over the past quarter to not only raise awareness but also share the lessons learned from recent JFSA and EMIR reforms.

We anticipate our Hong Kong community to begin preparations now that the window for feedback to its OTC reform consultation has closed. It is heartening to see this change already occurring, including customers engaging us to ignite conversations around sharing practical insights from other rewrite go-lives. Based on a tentative September 2025 go-live timeline, one key takeaway to factor in is that budgeting, resourcing, and internal business approvals (even info-security due diligence requirements down the road) involve a longer process so we strongly encourage firms to start having their internal conversations now.

With APAC stakeholders going through all these reforms at different times, it might feel like Groundhog Day every time they embark on a new regulatory project. Customers may want to exercise caution because while different regulatory reforms constitute similar major changes, often, the devil lies in the details.

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This article was published by S&P Global Market Intelligence and not by S&P Global Ratings, which is a separately managed division of S&P Global.