On 2 October 2026, the Financial Conduct Authority (FCA) published a consultation paper on preparing for the new transaction reporting regime (CP26/34).

Background

UK Markets in Financial Instruments Regulation (UK MiFIR) transaction reports are a key source of data for the FCA’s market monitoring, market abuse surveillance and supervisory activities. HM Treasury intends to repeal the existing UK MiFIR transaction reporting legislation, enabling the FCA to replace it with a new Handbook-based framework. CP26/34 follows publication of PS26/15: Improving the UK transaction reporting regime, which introduced the FCA’s new transaction reporting rules and confirmed that they will come into force on 3 April 2028.

CP26/34 is primarily an implementation consultation, focusing on how firms should prepare for and apply the new regime in practice rather than proposing further substantive policy changes. Alongside CP26/34, the FCA has separately published draft transaction reporting schema and validation rules to help firms prepare for implementation of the new regime.

Summary

CP26/34 contains a package of proposals intended to provide firms with greater certainty on how the new transaction reporting framework will operate in practice.

  • Transaction Reporting User Pack: The FCA proposes to create a new Transaction Reporting User Pack bringing together guidance, clarifications and reporting examples in a single resource. The final user pack will replace the relevant transaction reporting, instrument reference data and order record-keeping EU non-legislative materials currently contained within the FCA Handbook’s Level 3 materials section. The FCA believes this will make it easier for firms to locate and apply relevant guidance under the new regime.
  • New guidance on key reporting issues: As an initial step, the FCA is consulting on guidance in seven areas where it believes firms would benefit from greater clarity ahead of implementation.
  • Client indicator fields: guidance on the new client indicator fields introduced by PS26/15 and how these should be populated in a range of common reporting scenarios.
  • Conditional single-sided reporting (CSSR): clarification of reporting responsibilities between sending and receiving firms, including the treatment of client allocations and the population of buyer and seller fields.
  • Meaning of a transaction: further guidance on the concepts of acquisitions and disposals in derivative markets, including common lifecycle events such as increases and decreases in notional amount, partial terminations and full terminations.
  • Branch execution: guidance on determining whether a transaction has been executed wholly or partly through a UK branch, focusing on supervisory, governance and operational arrangements rather than solely on the physical location of a trader.
  • Equity swaps: clarification on reporting equity swap transactions, including use of the underlying reference price and reporting following the removal of the SwpIn and SwpOut indicators.
  • Strike price: guidance on use of the new value, NOAP, where a strike price cannot be determined at the point of execution.
  • Package transactions: guidance on the reporting of package transactions, including package identifiers, package pricing and the reporting of individual transaction legs.
  • Transitional provisions: The FCA is also consulting on new transitional provisions intended to provide certainty during migration to the new framework. These proposals address the treatment of transaction reports and instrument reference data submitted around the 3 April 2028 implementation date, including transactions executed shortly before implementation but reported afterwards. The proposals also cover corrections, reconciliations and record-keeping obligations following implementation.
  • Removing EU-only financial instruments from FCA FIRDS: The FCA is seeking views on the possible removal of financial instruments that are only tradeable on EU trading venues from the FCA Financial Instrument Reference Data System (FIRDS) ahead of implementation, subject to the necessary legislative changes.
  • Consequential amendments: The consultation proposes a range of consequential amendments across the FCA Handbook and associated Technical Standards. These amendments are intended to ensure that cross-references remain accurate following the replacement of the relevant UK MiFIR provisions in the Market Abuse Sourcebook (MAR) with record keeping (MAR 13), transaction reporting (MAR 14) and financial instrument reference data (MAR 15). Amendments are proposed across the Glossary, the Conduct of Business sourcebook (COBS), the Recognised Investment Exchanges sourcebook (REC), the Senior Management Arrangements, Systems and Controls sourcebook (SYSC).

Next steps

The FCA has asked for feedback by 6 November 2026. The FCA intends to publish a further consultation on the new Transaction Reporting User Pack in Q1 2027 and expects to publish the final user pack by 3 April 2027.