The FCA’s latest consultation, CP25/32, proposes a major overhaul of the UK MiFIR transaction reporting regime designed to streamline obligations and reduce compliance costs for firms. This marks a pivotal shift toward a more proportionate, UK-focused, and streamlined regime that reduces complexity, cuts costs, and improves clarity.
Transaction reporting has long been a source of operational complexity and costs for in-scope firms. This consultation signals a turning point, reflecting a commitment to reduce unnecessary burdens on reporting firms while maintaining market integrity. The changes are designed to support UK economic growth, reduce regulatory burden, and enhance the FCA’s ability to fight financial crime and protect market integrity.
The FCA’s Transaction Reporting Overhaul
On 21 November 2025, the FCA published Consultation Paper CP25/32 outlining proposals to streamline transaction reporting under UK MiFIR. These changes are designed to reduce complexity, enhance clarity, and support the UK’s competition agenda. Changes include:
Field Removals and Updates
- Removal of 13 redundant transaction reporting fields, including option type, maturity date, transmission of order, other indicator fields, and country of branch.
- Harmonization of terminology with UK EMIR by replacing the concept of a “complex trade” (i.e. a transaction in multiple financial instruments for a single price) with “package transaction”. The definition of a “package transaction” will be updated in the FCA handbook and the concept will require a separate transaction report for each reportable financial instrument or transaction separately, linked by a specific identifier. Two new fields will be introduced for package transactions.
Changes to Scope and Instrument Reportability
- Reporting will be limited to instruments tradeable on UK venues, saving firms an estimated £31.5 million annually. This will remove reporting obligations for 6 million instruments traded on EU venues. UK firms will no longer need to follow ESMA’s Traded on a Trading Venue (TOTV) opinion.
- Foreign Exchange (FX) derivatives will be removed from UK MiFIR reporting because UK EMIR reporting is deemed sufficient.
- Clarity is provided about structured products, indices, and baskets, with relaxed validation rules to ease compliance.
- The exemption for Collective Portfolio Management Investment (CPMI) firms to submit transaction reports will be retained because the overall cost of requiring the reports will not be offset by the benefit of the data.
Transmission and Reporting Simplification
- Amendments to the Article 4 Transmission regime create a mechanism for receiving firms to submit transaction reports on behalf of both parties, subject to certain conditions, including transfer of information.
- The FCA proposes reducing the back-reporting requirement from five years to three years, lowering operational burden for firms.
System and Data Enhancements
- Memorialisation of FCA Financial Instruments Reference Data System (FIRDS) as the golden source for determining reportability. The only exception is that any transaction executed on a UK trading venue is automatically in scope. It will explore the development of new functionality to improve usefulness and accessibility.
- Extension of the concept of ‘admission to trading’ to all types of trading venue (i.e. include Multilateral Trading Facilities (MTFs)) whilst allowing over-reporting for instruments pre-admission to trading. It is hoped this will reduce uncertainty regarding eligibility.
- Extensible Markup Language (XML) will be retained as the required messaging standard for transaction reporting, aligned with other reporting regimes. Improvements to the FCA’s Market Data Processor will be considered as part of a wider technology transformation project underway at the FCA.
Future Harmonisation Across MiFIR, EMIR, and SFTR
The consultation paper also signals a direction toward integrated reporting, outlining that the FCA has a long-term strategic vision for streamlining the framework across MiFIR, EMIR and Securities Financing Transactions Regulation (SFTR) reporting. Working with HM Treasury and the Bank of England, the FCA aims to reduce duplication and operational burden by moving towards a more integrated reporting framework.
While a single “report once” model is not being introduced immediately, the consultation outlines three guiding principles for future harmonisation:
- Data should only be collected where needed.
- A firm should only report data once.
- Data should be shared where appropriate.
The current proposals already reflect this approach. For example, the proposal that FX derivatives will be removed from MiFIR reporting is because UK EMIR data is considered sufficient for risk monitoring.
Looking Ahead
The FCA has outlined three initiatives to support the revised regime:
- Launch of a new transaction reporting user pack in 2026, providing firms with practical tools and guidance for implementation.
- Consult on aggregate client account (INTC) reporting guidance in 2026 to support firms.
- Establish a cross-authority and industry working group in early 2026 to design a streamlined model that simplifies overlapping reporting requirements and improves data quality across MiFIR, EMIR and SFTR.
Act Now to Ensure You Are Ready for the New Reporting Regime
The FCA suggested that final rules will be published in the second half of 2026, after which there will be an 18-month implementation window. These proposals will fundamentally change reporting obligations and firms that delay risk non-compliance, costly system rework, and operational disruption.
In-scope firms should do the following:
- Assess impact: Identify which reporting fields and instruments will be affected by the proposed changes.
- Update systems: Plan for adjustments to reporting technology and data management processes.
- Prepare for transition: Build a roadmap for implementation, factoring in the expected 18-month period after the policy statement is published.
The FCA’s consultation is open until 20 February 2026; affected firms are encouraged to respond.
Prepare for FCA Transaction Reporting Overhaul
The FCA’s consultation is more than a regulatory update, it’s a call for firms to rethink their reporting frameworks. Proactive planning will prevent costly remediation later and position your firm for success under the new regime.
Navigating regulatory change is complex. A specialist partner can help interpret requirements, design efficient compliance solutions, and ensure readiness without diverting critical resources from your core business. With ACA’s Regulatory Reporting Monitoring and Assurance (ARRMA) solution and expert guidance, you can ensure your current arrangements meet the new regulatory requirements whilst focusing on the future, turning compliance into a controlled and efficient process rather than a last-minute scramble.
ACA Delivers Confidence in MiFIR Reporting
With 93% of reporting submissions reviewed by ACA in 2025 containing at least one error, the time for firms to act is now.
ACA’S Regulatory Reporting Monitoring and Assurance (ARRMA) solution analyses reporting data to uncover issues with accuracy, completeness, and timeliness and provides actionable guidance to fix them. It’s a cost-effective way to build resilient, regulator-ready frameworks that stand up to scrutiny.
With ARRMA, firms can strengthen their reporting framework through:
- End-to-end oversight of EMIR and MiFIR reporting obligations
- Automated reconciliations to identify gaps and inconsistencies
- Audit-ready feedback with full traceability
- Specialist support to interpret and implement regulatory changes
ACA also provides targeted support across MiFIR reporting, including breach notification reviews, reconciliation testing, and governance enhancements.
Contact us today to book a free ARRMA review.