123. Clear and consistent identification of the products traded in the derivative transactions is one of the foundations of the efficient use of the derivative data. It enables the regulators to aggregate the reported transactions into desired groupings according to the products characteristics and in this way efficiently monitor exposures and risks related to distinct products or product categories.

124. It is crucial that the product identifier used in derivatives reporting fulfils a series of conditions, such as uniqueness, persistence, consistency, neutrality, reliability, open source, scalability, accessibility, availability at a reasonable cost basis, appropriate governance framework.

125. Furthermore, the global aggregation of OTC data will require the adoption of a globally UPI by the relevant jurisdictions. This is one of the key commitments made by G20 leaders with respect to the reforms of OTC derivatives markets.

126. Additionally, the empowerment for ESMA under Article 9(6) of EMIR as amended by EMIR REFIT to develop draft ITS explicitly requires ESMA to take into account international developments and standards agreed upon at Union or global level, therefore it is understood that ESMA needs to consider also the technical guidance on the UPI and the governance arrangements for the UPI.