On 3 August 2026, the Financial Conduct Authority (FCA) published its policy statement in relation to improving the UK transaction reporting regime (PS26/15).

Background

The FCA sets out that it considers that UK Markets in Financial Instruments Regulation (UK MiFIR) transaction reports are critical for its work to monitor financial markets, conduct market abuse surveillance and support supervisory activities and that HM Treasury plans to repeal UK MiFIR transaction reporting legislation, enabling the FCA to deliver a new, streamlined framework. In its November 2025 Consultation Paper (CP25/32), the FCA consulted on new rules in relation to this.

Summary

The FCA explains that having considered feedback to CP25/32 it will take the following approach, in particular:

  • Long-term approach to harmonisation: The FCA and Bank of England have launched an industry taskforce to develop a long-term, harmonised approach to transaction and post-trade reporting. Alongside plans to replace UK European Market Infrastructure Regulation (EMIR) over-the-counter (OTC) derivatives reporting requirements, the FCA also confirms that the regulators aim to align with international standards where appropriate.

Scope

  • Geographic scope: The FCA will narrow transaction reporting to instruments tradeable on UK venues only from 3 April 2028, following legislative changes. Until then, it will take a flexible supervisory approach regarding EU-only instruments. The FCA is also considering changes to the FCA Financial Instrument Reference Data System (FIRDS) and it will consult further with firms and provide an update in October 2026. The FCA will also remove reference to ‘Union’ including in Market Conduct Sourcebook (MAR) 14 Annex 2 and retain the current approach to national identifier hierarchy.
  • Foreign Exchange (FX) derivatives: The FCA will remove FX derivatives from UK transaction reporting, relying instead on UK EMIR data as a more effective monitoring tool and supporting reporting harmonisation. During the transition period to 3 April 2028, firms reporting under UK EMIR need not submit transaction reports, potentially reducing costs, while others must continue reporting.
  • Traded on a Trading Venue (TOTV) concept: The FCA will proceed with the proposed guidance and notes requests for examples and will consider these in the Transaction Reporting User Pack (TRUP).
  • Reporting financial instruments under UK MiFIR Article 26(2) (c): The FCA confirmed that it will proceed with the additional guidance as consulted. It also confirmed that where transactions are reported on a voluntary basis, they should be reported in line with applicable requirements for transactions in similar reportable financial instruments but that it is not introducing a prescribed list of reportable indices as that would be difficult to define and maintain.
  • Conditional single sided reporting (CSSR): The FCA will proceed with the CSSR framework, despite industry concerns, as it believes buy-side transaction data remains essential for market oversight, firm supervision and financial stability. The framework is optional and may particularly benefit firms already using Regulatory Technical Standard (RTS) 22 transmission arrangements and intra-group transactions. The FCA will monitor market impacts, adopt a pragmatic approach to data quality responsibilities, and provide further guidance to support consistent implementation.
  • Exclusions: The FCA will proceed with the proposals, clarify corporate action exclusions, retain reporting flexibility, and extend exemptions to all eligible post-trade risk reduction services, reducing complexity without affecting regulatory data needs.
  • Fractional Instruments: The FCA will proceed as consulted, clarifying the treatment of fractional instruments and providing examples in the TRUP to support consistent reporting and improved data quality.
  • OTC Derivative Identifiers: The FCA will retain OTC International Securities Identification Number (ISINs) for OTC derivatives, rejecting Unique Product Identifier adoption for now while reviewing wider OTC reporting reforms. It will support industry efforts to improve OTC ISIN template stability.
  • Meaning of a ‘Transaction’: The FCA will proceed with clarifying guidance linking transactions to changes in economic exposure. The changes codify existing expectations, do not expand reporting obligations, and will be supported by examples.
  • Meaning of ‘Execution of a Transaction’: The FCA will introduce the proposed guidance to improve consistency and codify existing practice. It emphasises that reporting expectations and the scope of reporting obligations remain unchanged.
  • Branch Execution: The FCA will proceed with new branch execution rules and guidance, providing additional principles-based examples in the TRUP to support firms with complex cross-border operating models.

Content of transaction reports

  • The FCA confirmed that it will proceed with most of the proposals in relation to the content of transaction reports as consulted on apart from changes to:
  • The FCA have updated its proposal in MAR 14.13.10G(2) to require the use of a trust Legal Entity Identifier (LEI) where one already exists. A transaction reporting firm may identify the beneficiary or beneficiaries of that trust only when a trust LEI does not already exist.
  • The FCA will not proceed with its proposal based on the feedback received and will instead codify the existing practice of using a central counterparty (CCP) LEI for transactions executed on a trading venue where the identity of the counterparty is not known at the point of execution. The segment Market Identifier Code of the trading venue should be used when the trading venue does not use a CCP.
  • In relation to trading capacity, the FCA will remove MAR 14.13.32R(3) as a result of the feedback but will make MAR 14.13.32R(1) and (2) as final rules.
  • In relation to systems and controls for transaction reporting, the FCA will add new guidance to provide clarity regarding its expectations for a transaction reporting incident management framework.

Obligations on trading venues

The FCA confirmed that it will move ahead with its proposals in relation to these obligations but will introduce a new code (‘NPEX’) to be used by trading venues in the Investment decision maker/execution decision maker fields to indicate that the investment or execution decision was made by a natural person, but that there is no requirement to identify them.

Next steps

The FCA sets out that the new regime will come into force on 3 April 2028 but that it will take a flexible supervisory approach from 3 August 2026 until this date in some areas to help firms benefit before 3 April 2028, as set out in Chapter 6 of PS26/15.