In August 2020 the FCA published its latest edition of Market Watch, issue 64, focussing on the implementation of MiFID II during the Brexit transition period.
Importantly, the FCA reminds firms that Brexit temporary transitional powers won’t be applied to transaction reporting rules under MiFID II. Therefore, firm and Approved Reporting Mechanisms (ARMs) must comply with changes to their regulatory obligations by the end of the transition period (31 December 2020). If firms and ARMs are unable to do this fully, they must back-report missing, incomplete or inaccurate transaction reports as soon as possible after the end of the Brexit transition period.
Additionally, to prepare for the post-Brexit transition state, the FCA notes that industry testing for the FCA’s Financial Instruments Transparency System will commence on 5 October and will remain open until December 2020, and the Financial Instruments Reference Data System (FCA FIRDS) is currently still available for testing. The FCA encourages firms and ARMs to interact with both platforms, and familiarise themselves with the dedicated webpages for each.