FCA finalises significant reforms to the UK transaction reporting regime to lock in predicted annual cost savings of more than £100m for the industry

The FCA has published Policy Statement PS26/15, confirming final rules which will significantly streamline the UK MiFIR transaction reporting regime. Firms will have until 3 April 2028 to implement the changes but will be able to apply certain changes (and benefit from associated cost savings) from now.  However, some of these amendments require changes to underlying validation rules (which the FCA will put forward in October 2026). Firms may wish to delay any early implementation until the validation rules are adapted to accommodate the rule changes, as they may otherwise experience rejections of their transaction reports.

Key changes include:

• removing FX derivatives from scope and limiting the scope to instruments tradeable on UK trading venues only (i.e. descoping instruments only tradeable on EU trading venues),
• providing further guidance on what amounts to the “execution” of a transaction – which could potentially bring additional flows in scope of reporting (despite FCA comments that they don’t intend to increase the existing scope),
• making the FCA FIRDS database the “golden source” for determining whether an instrument is subject to UK MiFIR transaction reporting,
• cutting the number of transaction reporting fields from 65 to 52,
• reducing the default back reporting period from 5 to 3 years,
• exempting most corporate actions from MiFIR transaction reporting,
• reducing the information to be reported by trading venues in transaction reports, and
• introducing a new Conditional Single-Sided Reporting (CSSR) framework to replace the current transmission exemption in the rules. 

The new regime will apply from 3 April 2028.  The FCA will publish new draft schema, validation rules and a new Transaction Reporting User Pack (which will contain examples to assist firms in complying with the revised requirement) in October 2026. This provides for an 18-month implementation period from the date the new schema have been provided to industry. Importantly, the FCA will apply a “flexible supervisory approach” which effectively allows firms to apply certain changes (and benefit from associated cost savings) immediately (or as soon as relevant validation rules have been amended). 

The FCA will continue to work on longer-term harmonization of transaction reporting requirements under UK MiFIR, EMIR and SFTR. This will involve industry engagement including through the Transaction and Post-trade Reporting Industry Harmonisation Taskforce (which has recently been set up). 

Read our briefing note for more detail on the policy statement.