FCA sets out reforms to transaction reporting

What does this mean?

The FCA proposes to replace onshored EU RTS 22/23/24 with new rules in its Market Conduct Sourcebook (MAR), as part of streamlining the MiFIR transaction transaction reporting regime. The FCA’s cost-benefit analysis estimates ongoing savings of about £115.3m per year, against one‑off implementation costs of about £148.8m.

Scope and interoperability 

The FCA proposes to retain buy‑side reporting but ease the burden via an expanded, simplified conditional single‑sided reporting model across all capacities (including dealing on own account and in matched‑principal capacity), reducing sender inputs to four core elements.

 The scope will be limited to UK‑venue instruments (removing EU‑only instruments) and will explicitly exclude FX derivatives from the reporting regime. The FCA will provide clearer UK guidance on ‘traded on a trading venue’ (TOTV), replacing reliance on ESMA’s MiFIR TOTV Opinion. Over-the-counter International Securities Identification Numbers will be retained (with Unique Product Identifiers under review for potential future alignment).

Transaction content and validation 

The FCA proposes targeted field removals, clearer quantity/price and client/trust guidance, limiting Trading Venue Transaction Identification Code to UK venues, requiring the segment Market Identifier Code where counterparties are unknown at execution (including Organised Trading Facility and organised  platforms outside the UK), adding package‑transaction price fields, and confirming consistent treatment for fractional instruments.

Key proposed changes

• Reduce reportable fields: Cut transaction reporting fields from 65 to 52, and instrument reference data fields from 48 to 37.

• Limit scope to UK‑venue instruments: Remove instruments only tradeable on EU venues from scope (cited in about 8% of 2024 reports).

• Exclude FX derivatives from MiFIR transaction reporting, relying instead on EMIR data and targeted ad hoc requests.

• Shorten default back‑reporting window from five to three years (retaining ad hoc up to five years for serious failings). 

• Remove low‑value or duplicative data fields (for example, the transmission indicator, changes in notional, option attributes, maturity date, a second notional currency, and other indicator fields). Add fields to identify package transactions and record package price/currency and align the ‘complex trade’ concept with the EMIR package‑transaction approach.

• Clarify exclusions with optional below‑threshold reporting: Exclude most corporate actions (initial public offerings, secondary offerings/placings, and debt issuance remain reportable); exclude dividend reinvestment plans; extend the exclusion for creation/redemption of collective investment undertakings to broker‑intermediated flows; set an employee share‑scheme de minimis of £1,500 per month with optional reporting below the threshold.

• Expand and simplify conditional single‑sided reporting across capacities, reducing sender‑provided data from ten to four elements.

• Permit voluntary over‑reporting of index derivatives to simplify eligibility assessments. 

• Confirm fractional instruments are in scope (e.g. fractional shares reported as equities with fractional quantity).

Data strategy and future vision

• CP25/32 lays the groundwork for broader data harmonisation across MiFIR, EMIR and SFTR. A cross‑authority working group will convene in 2026 to develop a streamlined long‑term framework based on principles such as data proportionality, international alignment and effective data sharing.

What do firms need to do?

The FCA’s proposals would reshape the UK MiFIR transaction-reporting landscape, creating a more focused regime with fewer reportable fields, a tighter scope around UK-venue instruments, and clearer guidance on core concepts such as TOTV and exclusions.

Operationally, an expanded conditional single-sided reporting model and shorter default back-reporting window should ease the burden on many firms. However, the regime will remain demanding, particularly for buy-side firms, which stay fully in scope and continue to face significant obligations around data quality, controls and oversight of any delegated reporting.

The proposed changes will drive system and interface changes, require updates to client and broker arrangements, and prompt a fresh look at how trade data is captured, enriched and reconciled. The forward-looking element is equally important: CP25/32 is positioned as a first step towards a more harmonised data model across MiFIR, EMIR and SFTR. 

The FCA’s proposed changes also raise strategic cross‑border considerations. Despite broad EU parallels, scope differences may fragment regimes, forcing dual builds, reconciliations across divergent data and validation rules, and higher exception risk. Firms should weigh a single harmonised build against jurisdiction‑specific stacks, under clear governance for mapping, testing and reconciliation.

Next steps

The consultation closes on 20 February 2026. The FCA plans to publish a Policy Statement in H2 2026, with an implementation period expected to be around 18 months. It will also consult on transitional provisions and consequential Handbook changes, consult on a new transaction‑reporting user pack in 2026, and establish a cross‑authority and industry working group, with further details due in Q1 2026.