The changes will reduce the scope and lessen the long-term compliance burden for firms, albeit with a short-term cost.
By Becky Critchley, Nicola Higgs, Rob Moulton, and Charlotte Collins
Link to Key Points: Key Points:
- The FCA has finalised changes to simplify the UK MiFID transaction reporting regime.
- Key changes include reducing reporting fields, removing certain instruments from scope, and reducing the period for back reporting from five to three years.
- The changes will take effect on 3 April 2028, although the FCA is taking a flexible supervisory approach that will enable firms to take advantage of many of the relaxations immediately.
On 3 August 2026, the FCA published its Policy Statement (PS26/15) on reforms to the UK MiFID transaction reporting regime. It previously consulted on these proposals in November 2025 (see this Latham blog post). According to the FCA, the proposals aim to significantly reduce the burden on firms subject to the transaction reporting regime; however, this claim has been contested by some market participants who find the proposals too timid. The FCA is largely taking forward its proposals as consulted on, although it has made certain adjustments in light of the feedback received, as outlined below.
In order to make these changes, new chapters 13, 14, and 15 of MAR in the FCA Handbook will replace Articles 25, 26, and 27 of UK MiFIR as well as the UK versions of RTS 22, 23, and 24. A helpful table in Annex 1 to the Policy Statement shows what has happened to each provision, as well as giving a high-level explanation (e.g., restated with amendments, restated with style changes, not restated). The FCA plans to set out its guidance on the regime in a new Transaction Reporting User Pack, which it will consult on in October 2026. The length and complexity of this document will be a significant clue as to whether the regime has been significantly improved, or whether one complex regime has been exchanged for another.
While there is a relatively lengthy implementation period to give firms time to make the necessary changes to their systems, firms can choose to benefit from many of the amendments now if they wish to. Whether they plan to utilise this flexibility immediately or not, the FCA recommends that firms start preparing for implementation now. They should also be mindful that these revisions signal meaningful divergence from EU MiFID and so must be ready to approach them as separate and distinct regimes. Although the FCA noted in its consultation that many firms already operate separate reporting systems, this will not be the case universally.
Link to Key Changes Key Changes
Link to Back Reporting Back Reporting
The FCA has confirmed it is reducing the period for back reporting erroneous reports from five to three years with immediate effect. While it considered reducing the reporting period further, it has concluded that a shorter period would risk limiting its oversight too severely. It explains that firms will be able to resubmit transaction reports for transactions executed under the current regime using the new schema after the new regime has been implemented. As proposed, the FCA will retain the ability to require back reporting on an ad hoc basis for up to five years (in relation to serious reporting failings), and firms will still be required to keep transaction records for five years. The regulator plans to provide transparency around the volume and nature of any such ad hoc requests via firm communications, including Market Watch.
The FCA is not taking forward calls to introduce a new “amend” function to correct historic transaction reports at this stage, as it considers implementation costs would outweigh the benefits. However, it may reconsider this approach in future.
Link to Geographic Scope Geographic Scope
The FCA is limiting the scope of the transaction reporting regime to financial instruments tradeable on UK trading venues only, noting that all respondents to the consultation supported this proposal. It estimates that this will remove reporting requirements for around 7 million financial instruments. Under its flexible supervisory approach, the FCA will not take action against firms that do not report transactions in financial instruments that are only tradeable on EU trading venues during the implementation period, allowing firms to benefit from the reduction in scope immediately.
However, the FCA acknowledges that many firms use FCA FIRDS to determine the scope of their reporting obligations and that, consequently, respondents requested financial instruments only traded on EU trading venues to be removed from FCA FIRDS. Therefore, it is considering removing EU financial instruments before April 2028, but wants to consider first whether this could create issues for firms that choose not to reduce the scope of their reporting before the official implementation date. It plans to provide an update on this aspect in October 2026 (when it plans to publish a further consultation).
A key significance of this proposal is that it may herald a similar scope change to MAR if and when the UK gets round to reviewing this regime too.
Link to FX Derivatives FX Derivatives
The FCA is removing FX derivatives from the scope of the transaction reporting requirements. This proposal received full support from all respondents, who agreed that UK European Market Infrastructure Regulation (EMIR) reporting requirements provide a better source of data for these markets. The FCA has not yet determined how to address the data gap this will leave in relation to UK branches of third-country firms, but plans to consider this as part of its work on restating the UK EMIR reporting requirements.
Firms that are subject to UK EMIR reporting requirements will not be required to report transactions in FX instruments under MiFIR during the implementation period. Firms which are not subject to UK EMIR reporting requirements, including UK branches of third-country firms, must continue to meet the MiFIR transaction reporting requirements until April 2028.
Link to Reporting Fields Reporting Fields
As proposed, the FCA is reducing the number of transaction reporting fields from 65 to 52. The FCA will not take action against firms that do not report these fields during the implementation period, in line with its flexible supervision approach. Other key amendments include:
- Limiting reporting of trading venue transaction identification codes (TVTIC) to transactions executed on UK trading venues. However, given the reporting issues, the FCA will monitor data quality in this area closely and conduct targeted supervisory work before deciding whether to make any further changes.
- Only requiring the use of a trust LEI where one already exists. If an LEI does not exist, the firm may identify the beneficiary or beneficiaries of that trust.
- Requiring firms to obtain national identifiers for natural persons before a service is provided.
- Confirming that the trading venue Market Identifier Code must be populated in the venue field for transactions which are negotiated away from, but brought under the rules of, a trading venue.
- Adding a new reporting value to indicate where a firm is providing direct electronic access.
- Replacing the complex trade field with a new package identifier field, based on a new definition of a package transaction.
However, based on the feedback received, the FCA is not taking forward its proposal to require firms to report the segment Market Identifier Code of the trading venue in the buyer and seller fields for all trading scenarios where the firm does not know the counterparty at the point of execution. Instead, it will codify the existing practice of using a central counterparty LEI for such transactions. The segment Market Identifier Code of the trading venue should be used when the trading venue does not use a central counterparty.
Also in response to feedback, the FCA will add new guidance around its expectations regarding firms’ transaction reporting incident management frameworks. However, it has declined to introduce a materiality threshold for the submission of breach notifications, as requested by some respondents.
Link to Changes for Trading Venues Changes for Trading Venues
The FCA will require trading venues to populate fewer fields in their transaction reports by removing 11 fields. It will also proceed with the proposal to align requirements for the “investment decision within firm” and “execution within firm” fields with the corresponding order book data fields.
Further, trading venues will only need to submit instrument reference data the first time there is a reportable event, plus for any subsequent changes.
The FCA is also progressing various other proposals, such as extending the concept of “admission to trading” to MTFs which undertake primary market activities, and removing derivative instruments from the concept of “admission to trading” where the trading venue is the issuer.
Link to Other Changes Other Changes
- Traded on a trading venue (TOTV): The FCA will provide new Handbook guidance in MAR 14 on what constitutes a reportable instrument, to assist firms with their reporting obligations in relation to OTC derivatives that are not executed on a trading venue. In response to feedback, it will consider including some examples in its Transaction Reporting User Pack.
- Index derivatives: The FCA will allow firms to “over-report” where the cost of determining the reportability of index derivatives may be greater than the cost of reporting the relevant transactions. However, the FCA has rejected the suggestion to publish a list of reportable indices. Further, firms will be able to report ISINs for all underlying instruments in a basket of derivatives, irrespective of whether these are in FCA FIRDS.
- Conditional Single-Sided Reporting (CSSR): The FCA is creating a new framework for CSSR, despite respondents voicing some significant reservations about the workability of such a model. The FCA stresses that CSSR is optional and that it considers it will still have various benefits. It plans to include examples for CSSR in different trading capacities in the Transaction Reporting User Pack.
- OTC derivative identifiers: The FCA will retain the OTC ISIN for derivatives, as proposed. Although it notes that around a third of respondents disagreed with its proposals, it does not consider it proportionate to implement the Unique Product Identifier as an identifier, as this could result in wasted effort if, for example, longer-term changes to reporting cause OTC derivatives to be reported under UK EMIR only.
- Exclusions: The FCA is expanding the scope of exclusions for corporate actions, regardless of whether an investment decision on the part of the investor is required. Firms can take advantage of this relaxation immediately. However, firms still have to report IPOs, secondary public offerings or placings, and debt issuances, and they can choose to report other corporate actions if this is less costly than excluding reporting. In response to feedback, the FCA has also widened the scope of the exclusions to include all eligible post-trade risk reduction services.
- Clarifications: The FCA is moving forward with its proposals to add clarificatory guidance on topics such as the meaning of “transaction” and “execution of a transaction”, and when a branch has executed a transaction.
- FIRDS:The FCA is taking forward its proposals to make FCA FIRDS a “golden source” for reportable transactions. It will limit a firm’s obligation to determine whether a transaction is reportable based on FCA FIRDS to T+7, irrespective of where the transaction was executed. However, it will not take action against firms if they reasonably assume an instrument is in scope despite not being available on FCA FIRDS. It is also exploring new functionality for FCA FIRDS.
Link to Implementation Implementation
The changes will take effect from 3 April 2028. A further consultation is expected in October 2026, which will include draft schema, validation rules, and new guidance in the Transaction Reporting User Pack, as well as transitional provisions and consequential amendments. This timing will mean that firms have 18 months for implementation once all supporting materials are available.
However, as noted above, the FCA is taking a flexible supervisory approach to certain elements of the transaction reporting framework with immediate effect. These elements are listed out in Chapter 6 of the Policy Statement and, in practice, allow firms to benefit from many of the relaxations immediately. For the avoidance of doubt, the FCA confirms that, from now on, firms are not required to correct errors or omissions, or notify it about issues, affecting areas in which it is taking a flexible supervisory approach.
The FCA estimates that, once the new regime is in place, annual industry costs related to transaction reporting will reduce from approximately £493 million to £385 million. However, firms will no doubt face significant short-term costs in recalibrating their systems to align with the revised requirements. The FCA recommends that firms start planning for implementation now by reviewing reporting logic, considering the impact of changes to scope and reporting fields, and preparing for the revised schema, validation rules, and guidance. In particular, the FCA suggests that firms should map trading scenarios against the revised requirements to understand which transactions remain reportable, which may fall out of scope, and which may require changes in terms of the data reported. However, the flexible supervisory approach should help firms to start to adjust to the changes and iron out any issues in advance of the official go-live date.
Link to Long-Term Approach Long-Term Approach
The FCA has also established a joint Transaction and Post-trade Reporting Industry Harmonisation Taskforce with the Bank of England to help shape the future approach; members of the Taskforce were announced in late July. The aim of the Taskforce is to inform the longer-term regulatory framework for reporting across relevant regimes, including UK MiFID, UK EMIR, and the UK Securities Financing Transactions Regulation, with a view to reducing complexity and duplication. The FCA reports that respondents to its consultation supported its suggestion of favouring incremental change over a complete redesign of reporting requirements, and were particularly keen to stress the importance of maintaining international alignment. Consequently, the FCA will work with the Taskforce to consider how incremental further improvements could be achieved in future.