The FCA has published Policy Statement PS26/15, “Improving the UK transaction reporting regime,” confirming its final rules following last year’s consultation CP25/32. The reforms mark the most significant changes to UK MiFIR transaction reporting since MiFID II. With simplification being the goal, the FCA estimates savings of more than £100 million a year for industry against an annual reporting cost it currently puts at £493 million.
What is changing
- Reportable fields cut from 65 to 52, plus removal of 11 instrument reference data fields for trading venues.
- Around 7 million financial instruments only tradeable on EU venues removed from UK reporting scope.
- FX derivatives removed from MiFIR transaction reporting entirely, with UK EMIR treated as the more appropriate regime for this data – cutting costs for over 400 UK firms and reducing duplication between regimes.
- Maximum back-reporting timeframe for correcting errors changed from 5 years to 3.
- Wider exemption for corporate event activity, other than IPOs, secondary offerings, placings and debt issuance.
- A new Conditional Single-Sided Reporting framework, intended to let more firms rely on transmission arrangements – though several buy-side respondents were sceptical it will deliver much practical relief.
- FCA FIRDS confirmed as the “golden source” for determining reportability, with a clear 7-day cut-off after execution (removes the obligation to continually check if a product has entered FIRDS and becomes reportable).
- The FCA wants to reduce the complexity of ascertaining the reportability of derivatives where the underlying is an index. The eligibility assessment will be simplified by permitting firms to voluntarily ‘over-report’ such transactions.
Timing
The new regime takes full effect on 3 April 2028. From 3 August 2026 until then, the FCA is taking a flexible supervisory approach across a defined list of areas, meaning firms will not face enforcement action for adopting several changes early – including the shorter 3-year back-reporting period, which applies immediately. A draft schema, validation rules and new guidance forming a Transaction Reporting User Pack are due in October 2026, and will shape system change planning ahead of the 2028 deadline.
Why it matters beyond MiFIR
The FCA has reiterated its ambition, shared with the Bank of England through a new joint Transaction and Post-trade Reporting Industry Harmonisation Taskforce, to build a single framework across UK MiFIR, EMIR and SFTR on the principle that a firm should only have to report data once. Removing FX derivatives from MiFIR’s scope in favour of UK EMIR is an early, concrete step in that direction. Firms should expect further consultations aimed at reducing overlap between regimes.
What reporting entities should do
No immediate action is required, but firms should begin preparing given the scale of the changes and the lead time involved. We will continue to track developments, including the October 2026 schema, and will keep clients updated as further detail emerges.
- Review reporting logic against the scope changes, particularly for FX derivatives and EU-only instruments.
- Assess data governance and reference data sourcing ahead of FIRDS becoming the golden source.
- Watch for the October 2026 schema and validation rule publication.
In the meantime, if you have any questions or require any further information, please get in touch with us.
