do so for the upi too within the next couple of months. the uti, by uniquely identifying each transaction, is essential to avoid double - counting und under - counting of transactions when aggregating data. the uti structure will be based on the lei of the generating entity, thus ensuring the uniqueness of each issued uti while allowing a plurality of generating entities. the upi – meanwhile – will allow flexible aggregation of different types of derivatives products by grouping various reference data elements, which are important for a specific analysis. consistent with the global dimension i mentioned at the beginning of my remarks, the cpmiiosco guidance refers to international standards, in particular iso, when applicable, in order to ensure international standardisation and a process for adapting the standard if needed. and the cpmi and iosco will also harmonise definitions and formats for a wide range of other critical data elements in the coming months. of course, this work is highly relevant to the global otc derivatives data aggregation effort, and for achieving the outcomes initially expected from tr reporting. yet, it could also serve purposes additional to the regulatory ones by, for example, simplifying pre - and post - trade processes performed by market participants and financial market infrastructures. additionally, the industry could easily leverage the upi by including more granular information on products, as needed for confirmation, risk management or other purposes. of course, globally harmonised data are of great interest to global market players, which would then have just one rule for all the jurisdictions in which they operate. the harmonisation approach followed by the cpmi and iosco is intended to be flexible and scalable to accommodate the evolution of markets, such as new products being traded, regulatory regimes and messaging standards. some jurisdictions such as the eu have introduced data harmonisation in contexts other than trade reporting – mifid ii for example – to support pre - and post - trade transparency. this reflects the fact that the same harmonised data may be used in different regulatory contexts and that such an approach simplifies data management by both authorities and the industry. consistent implementation of these standards should now be our priority. the fsb has set up a working group in charge of the governance for the uti and the upi, working in close collaboration with cpmi and iosco, so that implementation is achieved as swiftly and as consistently as possible across jurisdictions. the fsb has just started to publically consult on governance arrangements for a global uti.

3 in the case of the upi, a governance arrangement might involve some public / private interaction and collaboration, as seen with the lei. full implementation also requires removing legal barriers. in 2015, an fsb trade reporting peer review highlighted the need for fsb jurisdictions to remove legal barriers to the reporting of otc derivatives transactions to trs and to have legal frameworks in place to permit both domestic and foreign authorities ’ access to data held in a domestic tr by 2018. authorities announced last year their plans to remove such barriers. progress in that area is vital if we want the harmonisation efforts to bear fruit so that authorities are able to compile and make full use of tr data for their regulatory and / or supervisory mandates. 4 / 5 bis central bankers'speeches conclusion let me conclude. the benefits of data harmonisation and standardisation are clear : it will help authorities better monitor risks and give the private sector the basis for a deeper understanding of the financial markets, sounder decision - making, and increased process efficiency for industry participants. a lot has been done, but a lot more remains to be done. for example, more than three years since the start of emir data reporting, users and producers continue to face challenges. 4 these challenges include data quality aspects such as missing or misreported values, the double - reporting regime and the multiplicity of trs as well as the lack of standardisation and harmonisation across trade repositories and counterparties. 5 other issues relate to the reporting framework. for example, although some derivatives contracts, such as swaptions, have two maturity dates, there is only a single field for a maturity date. while work is ongoing to address some specific issues, a close, timely and effective interaction between users and drafters of statistical regulation will continue to be important. in my view, public / private collaboration remains the best approach for data harmonisation because both authorities and the financial industry alike are interested in achieving efficiency and quality. the use of international standards, where they exist or can be introduced, is likewise a good approach. this is particularly the case with a view to achieving worldwide recognition and adoption. for example, as a private sector mechanism, the iso has proven to be very effective, thanks to its strong governance and consultation process, involving most jurisdictions. such a mechanism could be one possible answer to the challenge of maintaining standardised data elements, provided that authorities are strongly and continuously involved. and, finally, there are still many implementation gaps