HKMA rewrite implementation

Expert Dialogues: Integrating with Confidence—Navigating the HKMA Rewrite

The HKMA OTC derivatives reporting rewrite, effective 29 September 2025, will introduce ISO 20022 XML submissions, global data standards such as UTIs and UPIs, and over 180 reportable fields—including detailed collateral requirements. The changes demand significant operational and technical upgrades, making early preparation and cross-team coordination essential.

Against this backdrop, I spoke with Nita Toh, APAC Implementation Lead at Cappitech, whose team plays a pivotal role in guiding clients through the complexities of such large-scale reporting transformations. Drawing on lessons from global rewrites and hands-on implementation experience, Nita shares how Cappitech’s tailored approach—combining robust onboarding, system mapping, and collaborative testing—helps firms navigate the HKMA changes with confidence and avoid the pitfalls of last-minute compliance.

Inside the Implementation Team at Cappitech

Thank you for joining us. Could you please introduce yourself and your role within Cappitech?

Nita: Thanks for having me. Our Implementation team’s mandate is to deliver smooth, secure, and scalable system implementations —from onboarding to live transaction reporting. We work closely with clients to connect trade data sources (APIs, SFTP, flat files, OMS/EMS systems) into the Cappitech platform and ensure those pipelines remain resilient and compliant.

How does your team support client onboarding and reporting readiness?

Nita: The length of time to onboard a client on to Cappitech can vary. A typical client implementation can span on average 8-10 weeks, starting with requirements gathering, system mapping, data validation, interface development, testing, and ongoing support. Using the upcoming HKMA rewrite project as an example, we coordinate technical, regulatory, and business stakeholders to ensure data flows correctly and reporting is accurate from kick-off as early as March this year. Key activities and milestones, including the approval of the “HKTR Nominated Agent,” the submission of the “HKTR Readiness Attestation,” and the re-reporting of legacy trades, are emphasized, supported, and closely monitored throughout the process. Clients receive essential assistance, which includes guidance documents, a comprehensive go-live runbook, and the initiation of a dry run for re-reporting requirements. These coordinated efforts are designed to ensure that clients are fully prepared and can smoothly transition to comply with the new HKMA Rewrite reporting requirements.

What capabilities differentiate Cappitech’s implementation offering? Can you walk us through a typical implementation journey?

Nita: Three core strengths:

  1. Flexibility: We support diverse data sources and formats with customized mapping to our normalized structure.
  2. Regulatory expertise: Our team blends technical delivery with deep knowledge of regimes like CFTC, CAD, EMIR, MiFID II, SFTR, JFSA, MAS, ASIC, HKMA, etc.
  3. Cappitech Consulting synergies: With Cappitech Consulting providing expert interpretation of regulations, guidance on industry best practices, and health check support, clients get seamless implementation, data enrichment, validation processes, dashboarding, and full lifecycle support.

Happy to walk through an implementation project. In six steps:

  1. Requirement gathering: Identify reporting scope, frequency, instrument eligibility.
  2. System mapping: Chart and mapping of client data sources to regulatory requirements — trading systems, files, APIs.
  3. Data validation: Check completeness, format, identifiers like LEIs or NCIs.
  4. Building interfaces: APIs, upload pipelines, transformation logic.
  5. Testing: Validate in sandbox or test environment, run edge cases.
  6. Go‑live & support: Monitor feeds, resolve exceptions, adjust to regulation changes over time.

How do you help clients maintain compliance as regulations evolve?

Nita: We keep clients future‑proofed via:

  • Pre-emptive updates from the Cappitech Product and Consulting teams for rule changes (e.g. MAS, ASIC and now HKMA validation updates).
  • We adopt a global working group approach in close collaboration with regulators and TRs.
  • Enhancements built into the platform (data enrichment, exception dashboards, reconciliation tools) to adapt quickly with minimal client friction.

Clients benefit from our aggregated institutional experience: >10% of EU trading volume processed, >85% exceptions identified early, up to 70% reduction in total cost of ownership.

Interviewer: What’s the most challenging aspect of implementation and how do you overcome it?

Nita: Dealing with heterogeneous source systems and inconsistent trade-level data is our biggest challenge. Clients might also not be familiar with their internal systems and thus time has been spent to sort out the complexities. We mitigate this with:

  • A robust requirement and mapping phase,
  • Automated validation logic and reconciliation tools,
  • And proactive communication with the client’s technical stakeholders to resolve edge-case formats early, as well as cite examples of potential delays.

Any client feedback or notable success stories?

Nita: Yes — many clients comment that Cappitech onboarding was faster and smoother than competitors. One mentioned going fully compliant in just 6 weeks post‑contract, thanks to our implementation and onboarding methodology, as well as some of the initial works that we can carry out just to manage a tight timeline. Our systematic and hands‑on approach consistently delivers a high‑ quality, low‑touch experience.

Interviewer: Finally, what excites your team most about the future of implementation at Cappitech?

Nita: We’re excited about scaling automation and embedding intelligent adaptation:

  • Leveraging AI for client data analysis and mapping. Ultimately shortening the onboarding timeframe and making it an overall better client experience.
  • AI-driven reconciliation – to ensure completeness, accuracy on client report submissions
  • Automated enrichment of UPIs across global regimes
  • And deepening industry collaboration to shape future regulatory standards.

I firmly believe implementation at Cappitech is not just plugging in systems—it’s helping organisations evolve into frictionless, resilient compliance partners for regulators worldwide.

Interviewer: Thank you, Nita, for sharing this insightful look into your Implementation Team’s role at Cappitech.

Charles Foo
About the author: Charles Foo
Charles serves as Director, APAC lead for Business Development within S&P Global Market Intelligence Cappitech and is responsible for leading the growth of the regulatory reporting capabilities in Asia. His 15-year capital market experience spans across middle office, G20 regulatory reporting and post-trade securities processing.