The FCA turned its spotlight on the UK MiFID (Markets in Financial Instruments Directive) transaction reporting regime in the recent edition of Market Watch. With a timely reminder of the importance of robust, timely, and transparent regulatory reporting, the insights are also relevant for firms reporting under UK EMIR (European Market Infrastructure Regulation) and SFTR (Securities Financing Transactions Regulation).
The FCA requests that firms integrate lessons from this Market Watch “into their existing processes to support efficient transaction reporting.” Below outlines their observations from the transaction reporting regime and how to avoid similar issues in your reporting.
Reporting Timeliness Matters
The FCA is increasingly concerned about delays in addressing known reporting issues. Common pitfalls include:
- Missed deadlines and slow remediation plans.
- Fragmented ownership and siloed teams.
- Reactive compliance cultures and weak governance.
Back Reporting: A Risky Blind Spot
Correcting historical data (back reporting) is often overlooked or deprioritised. The FCA warns that:
- Delays can hinder market abuse detection.
- System migrations often lead to inaccessible archived data.
- Poor governance can result in ineffective remediation.
Breach Notifications: Quality Over Quantity
With 241 breach notifications in Q1 2025 alone, the FCA is flagging submissions for quality. Many submissions lack the depth needed to demonstrate that firms have properly understood and addressed the issue. Notifications that omit root cause, impact, or governance oversight fall short of regulatory expectations and hinder the FCA’s ability to assess the seriousness of the breach.
Appropriate notifications should include:
- Clear root cause analysis.
- Accurate scope and impact.
- Defined remediation and governance oversight.
Practical Steps for Regulatory Success
The FCA’s message is clear: effective reporting is not just about systems, it’s about culture, governance, and accountability. Firms that invest in proactive, well-governed reporting frameworks will be better positioned to meet regulatory expectations and protect market integrity.
To stay ahead of regulatory expectations, firms should:
- Act swiftly on known issues.
- Prioritise root cause analysis over surface level fixes. Remediation can be costly; it is in the firm’s best interest to get reporting right the first time.
- Ensure governance accountability. Escalation points for reporting issues must be clear, and senior management must own the remediation journey.
- Treat back reporting as critical rather than optional.
- Submit high-quality breach notifications. Include all requested information and make notifications clear, complete, and timely.
Take Control of Your Regulatory Reporting
At ACA, we understand the complexity and constant evolution of regulatory reporting. That’s why we developed ACA’s Regulatory Reporting Monitoring and Assurance (ARMMA) solution.
With ARRMA, you get:
- End-to-end oversight of your EMIR and MiFIR reporting obligations.
- Automated reconciliations to identify gaps and inconsistencies.
- Real-time exception management and alerts.
- Audit-ready reporting with full traceability.
- Specialist support to interpret and implement regulatory changes.
Book a free review to discover how ACA can help you reduce operational risk, improve data quality, and stay compliant—no matter how often the rules change. ARRMA identifies transaction reporting errors and provides practical advice/support to resolve them.
This cost-effective solution is designed to analyse the data included in your firm’s reports and identify issues relating to accuracy, completeness, and timeliness.
With 93% of reporting submissions reviewed by ACA in 2025 containing at least one reporting error, the time for firms to act is now.