On 21 November, the Financial Conduct Authority (FCA) published a consultation paper (CP 25/32) setting out proposals to improve the UK transaction reporting regime.

Background

The transaction reporting rules in the Markets in Financial Instruments Regulation (MiFIR) were implemented in 2018 and on-shored following the Brexit transitional period on 31 December 2020. In November 2024 the FCA published DP24/2 in relation to improving the UK transaction reporting regime. The FCA has now set out in CP 25/32 the changes it is proposing to make to this regime in response to feedback to that discussion paper.

In addition, the FCA has explained in CP 25/32 that it is also outlining a cross-authority vision with HM Treasury and the Bank of England on a new long-term, strategic approach to streamlining transaction reporting requirements across multiple regimes, including requirements in the UK European Market Infrastructure Regulation (EMIR) and the UK Securities Financing Transactions Regulation (SFTR).  

Key proposals

The FCA sets out in CP25/32 that key proposals it is consulting on in relation to improving transaction reporting include:

  • Reducing the number of transaction reporting fields from 65 to 52.
  • Removing reporting obligations for 6 million financial instruments which are only tradeable on EU trading venues.
  • Removing foreign exchange (FX) derivatives from the scope of reporting requirements, reducing costs for over 400 UK firms.
  • Reducing the default back reporting period from 5 to 3 years to lower the number of transaction reports that need to be resubmitted to the FCA by a third.
  • Requiring trading venues to populate fewer fields in their transaction reports, simplifying information provided by over 1,700 international firms.
  • Reducing the number of instrument reference data fields from 48 to 37.
  • Removing the obligation on systematic internalisers to submit instrument reference data, as these firms current submit one third of the instrument reference data received by the FCA.

Next steps

The FCA has asked for comments on CP 25/32 by 20 February 2026.

The FCA also sets out that it plans to publish a policy statement finalising its new transaction reporting rules in the second half of 2026 and that it will confirm an implementation period for the changes in that policy statement, which it intends to be approximately 18 months.

In addition, the FCA also made clear that it will be establishing a cross-authority and industry working group to inform the design of its long-term approach to transaction reporting and will give further information about the terms of reference and application process for this group in the first quarter of 2026.