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Key Takeaways
- CP26/34 is the FCA’s next consultation on implementing the new UK MiFIR transaction reporting reform. It covers proposed guidance, transitional provisions, and consequential amendments ahead of the new regime.
- The consultation closes on 6 November 2026. Firms should consider whether the proposed guidance, transitional arrangements, and examples provide sufficient clarity for implementation.
- The FCA has published draft schema and validation rules. Firms can now begin assessing the impact on reporting logic, data, systems, governance, and controls.
- The new UK transaction reporting rules take effect on 3 April 2028. The FCA plans to consult on its Transaction Reporting User Pack (TRUP) in Q1 2027 and publish the final version by 3 April 2027.
- Simplified reporting does not reduce the need for strong controls. Firms remain responsible for accurate, complete, and timely transaction reporting and should use the implementation period to identify gaps early.
- A structured readiness review can help firms assess reporting logic, data, systems, governance, and controls before deadlines become critical.
The FCA’s consultation paper, CP26/34, Preparing for the New Transaction Reporting Regime, marks the next step towards replacing the current UK MiFIR transaction reporting framework.
While the core policy reforms were finalised in PS26/15, this consultation focuses on how firms should prepare for implementation and transition ahead of the 3 April 2028 go-live date. Firms have until 6 November 2026, to respond to the consultation.
April 2028 may seem distant, but firms will need to start the operational and data work well in advance. The consultation provides an early view of proposed guidance, technical standards, validation rules, and transitional arrangements that will shape implementation.
The FCA has also confirmed that it will consult on a new TRUP in Q1 2027, before publishing the final version by 3 April 2027, giving firms a further opportunity to understand regulatory expectations ahead of implementation.
Data Quality Remains Central to Transaction Reporting
The FCA describes transaction reports as a critical source of information for market monitoring, market abuse surveillance, and supervisory activities. While the new framework aims to streamline reporting and reduce unnecessary complexity, firms will still need to submit accurate, complete, and consistent transaction reports.
CP26/34 is primarily focused on helping firms apply the new rules consistently.
The consultation proposes:
- Guidance on key areas of the new reporting framework
- Transitional provisions for moving from the existing regime
- Consequential amendments to Handbook rules and technical standards
- A new TRUP that will consolidate relevant reporting guidance and examples into a single resource
These proposals provide an early basis for compliance, operations, and technology teams to assess reporting logic, data requirements, systems, governance, and controls against the future regime.
Key Dates in the Implementation Timetable
Firms Need to Start Preparing Now
Reporting reform programmes can involve significant operational dependencies. Firms should use the implementation period to review reporting logic, field population methodologies, governance arrangements, validation processes, and reporting controls. Even where firms outsource reporting, accountability for accuracy, completeness, and timeliness remains.
The FCA has already published draft schema and validation rules to support industry preparation. This gives firms an opportunity to begin impact assessments well before the 3 April 2028 implementation date.
Early preparation can help reduce the risk of late-stage remediation, testing bottlenecks, and reporting defects as implementation approaches.
The Implementation Roadmap Is Already Taking Shape
The implementation timeline provides firms with several important milestones. The immediate priority is reviewing CP26/34 and considering whether to respond before the 6 November 2026 deadline. Firms should then plan for the FCA’s Q1 2027 consultation on the TRUP, which is intended to bring together relevant transaction reporting guidance, instrument reference data guidance, and reporting examples into a single resource.
By the time the FCA publishes the final TRUP on 3 April 2027, firms should be progressing their gap analysis, operating model design, and technology planning.
This staggered timetable gives firms time to validate assumptions, refine implementation plans, and address potential reporting challenges ahead of the 3 April 2028 implementation date.
A Structured Review Can Identify Reporting Gaps Early
- Conduct a reporting impact assessment: Assess how the new rules affect existing transaction reporting processes, controls, and governance arrangements.
- Map reporting data requirements: Compare current reporting fields against the proposed schema and validation requirements to identify data gaps.
- Review technology architecture: Evaluate whether reporting platforms, workflows, and interfaces can support the future reporting model.
- Test governance and controls: Assess ownership, escalation procedures, exception management, and reconciliation processes.
- Engage with implementation stakeholders: Bring together compliance, operations, technology, front office, and reporting teams to establish a coordinated implementation programme.
- Monitor future FCA publications: Track developments relating to the consultation process, draft guidance, the upcoming TRUP, and final technical specifications.
Implementation Requires More Than a Technology Change
One of the key themes of CP26/34 is consistency. The FCA’s proposals are intended to support consistent application of the new reporting rules during and after implementation.
Achieving that objective will require more than system updates. Firms should consider clear governance, documented reporting decisions, effective testing, and ongoing oversight of reporting quality. Early planning can help firms identify implementation issues well before the 3 April 2028 implementation date.
Early Preparation Can Reduce Implementation Risk
CP26/34 gives firms an early opportunity to understand the FCA’s expectations and begin preparing for a significant reporting transformation. The consultation deadline in November 2026, the expected TRUP consultation in Q1 2027, and the publication of the final TRUP in 3 April 2027 create a structured path towards implementation.
Firms that use these milestones effectively are likely to face fewer surprises, lower implementation risk, and a smoother transition when the new regime takes effect on 3 April 2028.
Assess Your Transaction Reporting Readiness
Specialist support can help you assess how the reforms affect your reporting framework and identify practical ways to streamline processes, strengthen controls, and prepare for implementation.
ACA’s Regulatory Reporting Monitoring and Assurance (ARRMA) solution includes a free transaction reporting review, providing an independent assessment of the accuracy, completeness, and timeliness of your transaction reporting. It can highlight areas that may need attention ahead of reform implementation.
The review also gives you an opportunity to discuss the findings with an ACA specialist, including the impact of the new regime and practical next steps.
Frequently Asked Questions
What is FCA CP26/34?
CP26/34 is the FCA’s consultation on proposed guidance, transitional provisions, and consequential amendments to support the new UK transaction reporting regime.
When do the new UK transaction reporting rules take effect?
The new rules take effect on 3 April 2028. Before then, the FCA plans to consult on its Transaction Reporting User Pack (TRUP) in Q1 2027 and publish the final TRUP by 3 April 2027.
What is the FCA’s Transaction Reporting User Pack?
The FCA intends for the TRUP to bring together the relevant reporting guidance, clarifications, and examples in one resource to help firms apply the new regime consistently. The FCA plans to consult on it in Q1 2027 and publish the final version by 3 April 2027.
What should firms do now to prepare for UK transaction reporting reform?
Firms should use the implementation period to assess the impact on their reporting logic, data, systems, governance, and controls. The FCA has also published a draft schema and validation rules to support that work.
How can firms assess their transaction reporting readiness?
A structured review should consider reporting accuracy, completeness, and timeliness, alongside reportability logic, data, systems, governance, and controls. A free ACA Regulatory Reporting Monitoring and Assurance (ARRMA) review can help identify areas requiring attention and provide an opportunity to discuss the impact of the new regime with an ACA Specialist.