The FCA has finalised changes to the UK's transaction reporting regime following a consultation last year. The regulator estimates that the industry currently spends £493 million annually on transaction reporting and expects the reforms to save more than £100 million a year.
These are arguably the most significant changes to UK MiFIR transaction reporting since MiFID II came into force in 2018.
London's trading industry is coming home!
That is welcome news. However, anyone who has been through EMIR Refit will know that simplification does not necessarily mean less work. Changes to reporting schemas, new validation rules and months of regression testing can quickly offset some of the expected savings.
Much of the reduction in trade repository charges could be absorbed by the personnel time required to adjust to the new specifications.
What Is Changing?
The main changes fall into three areas: what firms must report, which instruments fall within scope and how far back firms must correct reporting errors.
The number of reportable fields will fall from 65 to 52. Trading venues will also no longer need to provide 11 instrument reference data fields.
The scope of reporting will become narrower, with around seven million instruments that are tradable only on EU venues removed from UK reporting requirements.
Another significant change concerns FX derivatives, which will be removed from MiFIR transaction reporting altogether. The FCA considers UK EMIR a more appropriate reporting framework for this data. The change is expected to reduce costs for more than 400 UK firms while removing duplication.
- BtcDana's UAE Entity Secures CMA Category 5 Licence for Client Introductions and Promotion
- “The Higher the Traffic, the Higher the Trading Volume” Is Not a Given, FM Intelligence Finds
- Interactive Brokers Reports 4.3 Million DARTs in October as Monthly Activity Rises 5%
The maximum period for correcting historical reporting errors will also fall from five years to three. In addition, the exemption for corporate events will be widened, although IPOs, secondary offerings, placings and debt issuance will remain reportable.
For retail FX and CFD brokers, the removal of FX derivatives from MiFIR reporting is arguably the most important change. Reporting the same transaction under two separate regimes, using different formats and sending the data to different destinations, has long been one of the less defensible aspects of the UK reporting framework.
Why Does FIRDS Becoming the Golden Source Matter?
The FCA has confirmed that its Financial Instruments Reference Data System will become the definitive source for determining whether an instrument is reportable. A clear seven-day cut-off after execution will also apply.
In practice, this should remove the need for firms to keep checking whether an instrument has entered FIRDS and become reportable after a transaction has taken place.
However, placing greater reliance on FIRDS also increases the importance of data governance. Firms will need to understand where their reference data comes from, how frequently it is refreshed and who is responsible for managing it internally.
The FCA is also addressing reporting requirements for derivatives on indices, where determining whether a transaction is reportable can be difficult. Firms will be allowed to voluntarily over-report these transactions.
For many brokers, reporting all transactions in this category may prove simpler and less expensive than developing systems to determine which ones fall outside the reporting requirements.
Will Conditional Single-Sided Reporting Deliver Real Relief?
PS26/15 introduces a new Conditional Single-Sided Reporting framework. Its purpose is to allow more firms to rely on reporting arrangements with counterparties instead of reporting the same transaction twice.
The direction is welcome, but there are reasons to question how much relief the framework will deliver in practice. Several buy-side respondents told the FCA that they were sceptical about its potential benefits.
Delegating reporting responsibilities to a counterparty may appear straightforward. However, it requires accurate data sharing, clearly defined responsibilities and appropriate contractual arrangements. Without these elements, firms risk replacing one operational burden with another.
Ultimately, the framework's value will depend on the conditions attached to it and how easily firms can meet them.
When Do the Changes Take Effect?
The new reporting regime will become fully effective on 3 April 2028. However, firms should pay attention to three dates in the implementation timeline.
From 3 August 2026, the FCA is adopting a flexible supervisory approach across a defined list of areas. Firms will not face enforcement action for adopting several of the changes early. The shorter three-year back-reporting period also applies from this date.
In October 2026, the FCA is expected to publish a draft schema, validation rules and updated guidance. Together, these documents will form the Transaction Reporting User Pack.
Full implementation will follow on 3 April 2028.
The October 2026 publication is particularly important. Until firms have access to the revised schema and validation rules, they can assess the scope of system changes but cannot begin building against the final technical specifications.
Why Does This Matter Beyond MiFIR?
The reforms are also part of a broader effort to simplify regulatory reporting in the UK.
The FCA and the Bank of England have established a joint Transaction and Post-trade Reporting Industry Harmonisation Taskforce. Its objective is to develop a single reporting framework covering UK MiFIR, UK EMIR and UK SFTR.
The underlying principle is straightforward: firms should only have to report data once.
This could eventually address some of the overlap between the three reporting regimes. Firms should therefore expect further consultations as regulators explore ways to harmonise their requirements.
How Should Firms Prepare?
Although the FCA does not require firms to take immediate action, the scale of the changes and the time needed to implement them make it unwise to wait until 2028.
Reporting teams and their external service providers should already be reviewing their existing arrangements.
In particular, firms should:
- Review reporting logic against the revised scope, with particular attention to FX derivatives and instruments traded exclusively on EU venues.
- Assess data governance arrangements and reference data sources ahead of FIRDS becoming the definitive source for determining reportability.
- Check whether correction and back-reporting procedures reflect the new three-year limit, which already applies.
- Monitor the publication of the October 2026 schema and validation rules, and allocate sufficient time and resources for the necessary system changes.
PS26/15 represents a step towards a leaner UK transaction reporting regime. The expected reduction in reporting costs is welcome, particularly for firms that have had to manage overlapping requirements across different regulatory frameworks.
However, the savings will not come automatically. Firms still face the work of updating systems, reviewing data processes and ensuring that their reporting arrangements meet the revised requirements.
Those that use the next 18 months to review their data, map reporting flows and prepare for the technical changes should be in a better position to benefit from the reforms. Those that wait until 2028 risk turning a simplification exercise into another last-minute compliance project.
