Key Takeaways
- The FCA has finalised major reforms to the UK MiFIR transaction reporting regime.
- Reporting will focus on financial instruments traded on UK trading venues.
- FX derivatives will no longer be reportable under UK MiFIR.
- The FCA will reduce reportable fields from 65 to 52.
- Firms should begin assessing reporting logic, systems, and data quality controls well before the April 2028 implementation date.
The FCA has finalised one of the most significant overhauls of the UK MiFIR transaction reporting regime since Brexit. Through Policy Statement 26/15, the regulator is reducing reporting complexity, removing data fields that deliver limited supervisory value, and narrowing the scope of reportable instruments. The new framework comes into force on 3 April 2028, with supervisory flexibility beginning on 3 August 2026.
These reforms are relevant to UK firms and international firms subject to UK MiFIR transaction reporting obligations, as well as their heads of compliance, CCOs, COOs, operations leaders, and transaction reporting teams.
At first glance, the reforms appear to focus on reducing reporting obligations. In reality, they represent a broader shift in regulatory priorities. The FCA is streamlining the regime by removing requirements that contribute little to market surveillance while raising expectations around the quality and reliability of the data firms continue to submit. For compliance and operations teams, success will depend less on reporting volume and more on the strength of underlying controls.
The reforms simplify reporting while maintaining the FCA’s focus on data quality and governance. Many of the changes remove requirements that firms have long viewed as costly, burdensome, or duplicative.
At the same time, the regulator is tightening expectations in areas that directly support market surveillance and data quality. For firms with UK transaction reporting obligations, the challenge is no longer just compliance. It is understanding where operational effort can be reduced and where controls need to become stronger.
The final package also reflects the FCA’s willingness to respond to industry feedback. While it has retained reforms it considers fundamental to market oversight, such as conditional single-sided reporting, it has also refined several proposals to reduce unnecessary complexity and focus reporting requirements where they deliver the greatest supervisory value.
The FCA Is Narrowing the Scope of UK MiFIR Transaction Reporting
Several reforms will significantly reduce the population of reportable transactions. Most notably, transaction reporting will be restricted to financial instruments traded on UK trading venues. Approximately seven million instruments that are only traded on EU venues will fall outside the UK reporting regime. The FCA has also confirmed that it will remove foreign exchange (FX) derivatives from the scope of transaction reporting altogether, citing the availability of equivalent data through EMIR reporting.
For many firms, this could lead to a material reduction in transaction volumes, operating costs, and exception management.
The FCA has also provided much-needed clarification around the “traded on a trading venue” assessment for over-the-counter (OTC) derivatives. By setting out a clearer methodology for comparing instrument reference data, firms should find it easier to determine whether certain over-the-counter derivative transactions remain reportable.
Fewer instruments will require reporting, but firms must revisit their reportability logic and instrument classification frameworks to ensure they capture the revised scope correctly.
Conditional Single-Sided Reporting Remains the Most Debated Change
Despite significant industry pushback, the FCA is proceeding with Conditional Single-Sided Reporting (CSSR). Under this framework, certain firms may be able to rely on another party to submit transaction reporting data, reducing duplicate reporting.
Many respondents raised legitimate concerns around:
- Managing data-sharing arrangements
- Establishing contractual protections
- Reconciling transmitted information
- Handling data quality issues
- Operating different reporting models across jurisdictions
However, the FCA believes CSSR has the potential to reduce unnecessary reporting while maintaining access to critical market surveillance information. It also notes that most reports currently submitted do not contain personally identifiable information, potentially increasing the number of scenarios where CSSR could be practical.
CSSR will not be appropriate for every firm. However, firms that execute high volumes of inter-affiliate or institutional transactions should assess whether it could deliver meaningful operational efficiencies.
The FCA Is Reducing Transaction Reporting Fields While Raising Data Quality Expectations
Chapter 4 delivers one of the most visible changes. The FCA will reduce the number of transaction reporting fields from 65 to 52 through the removal of data elements considered to provide limited supervisory value. These include fields relating to option characteristics, maturity dates, waiver indicators, short-selling indicators, securities financing transaction indicators, and several other fields.
Visual SnapshotÂ
| As of August 2026 | Effective April 2028 |
|---|---|
| 65 reportable fields | 52 reportable fields |
| Broader instrument scope | UK-venue focus scope |
| FX derivatives reportable | FX derivatives removed |
| Five-year default back–reporting period | Three-year default back-reporting period |
| Two-sided reporting | CSSR available in certain scenarios |
While firms will welcome a simpler reporting framework, these changes should not be interpreted as a relaxation of regulatory expectations. The FCA is reducing the volume of information firms need to report while raising the bar for the accuracy, completeness, and consistency of the data that remains.
Firms will be expected to validate client, trust, and natural-person identifiers before executing reportable transactions, ensure key reporting fields remain internally consistent, and maintain robust governance over reporting quality.
For many firms, success will depend less on submitting more reports and more on strengthening the controls and validation processes that underpin transaction reporting.
The FCA Clarifies Transaction Reporting Rules
One of the most practical aspects of PS26/15 is the additional guidance provided across several areas that have historically created uncertainty.
The FCA has clarified:
- What constitutes a reportable transaction
- When a transaction is considered executed
- How branch execution responsibilities should be assessed
- How fractional instruments should be reported
- How certain index and basket derivatives may be treated for reporting purposes
These changes do not materially expand reporting obligations. Instead, they codify existing regulatory expectations and market practice, helping firms apply the rules more consistently.
Firms Should Prepare Now
Although implementation is not scheduled until April 2028, firms should not wait until the final deadline.
Many of the benefits promised by the reforms will only be realised through careful planning and controlled implementation.
For many firms, implementation will involve more than updating reporting rules. Changes may be required across reportability logic, instrument reference data, transaction reporting systems, Approved Reporting Mechanism (ARM) interfaces, reconciliation processes, and data quality controls.Â
Early impact assessments can help firms identify where system changes, testing, and governance updates will be needed ahead of implementation.
Practical Steps Firms Should Take Now
- Assess how the revised scope affects reportability rules and product inventories
- Review transaction reporting policies and procedures against the new requirements
- Evaluate CSSR use cases and operational feasibility
- Identify systems impacted by field removals and reporting logic changes
- Review client onboarding controls for natural-person identifiers
- Validate trust and entity identification processes
- Conduct targeted data quality testing before implementation
- Develop a transition roadmap aligned to the FCA timetable
Firms that start planning early will be in a stronger position to achieve cost savings while avoiding remediation work closer to implementation.
The Implementation Period Creates an Opportunity to Strengthen Transaction Reporting Controls
The FCA has indicated that it will adopt a pragmatic supervisory approach during the transition period, recognizing that firms need time to update their systems and controls. However, this flexibility should not be mistaken for a delay in expectations. Firms that use the implementation period to strengthen governance, improve reporting quality, and simplify reporting architectures are likely to see the greatest long-term benefits.
The UK MiFIR Changes Go Beyond Compliance
PS26/15 is ultimately a modernisation programme. The FCA wants a transaction reporting regime that delivers high-quality data while reducing unnecessary operational burden.
For many firms, the challenge will not be understanding the new rules. It will be translating those rules into effective controls, governance arrangements, and reporting processes. This is where independent expertise can add significant value, helping firms identify gaps, prioritise remediation, and implement sustainable reporting frameworks.
ACA Helps Firms Prepare for UK MiFIR Transaction Reporting Changes
ACA supports firms throughout the transaction reporting lifecycle, from regulatory interpretation through to operational implementation.
Our services include:
- ARRMA (ACA’s Regulatory Reporting Monitoring and Assurance solution) reviews to evaluate transaction reporting risks, controls, governance arrangements, and data quality, helping firms identify gaps and prioritise remediation before regulatory issues arise. This includes a complimentary initial review to help firms identify priority areas for remediation.
- Policy rewriting to align reporting frameworks with new FCA requirements and clearly document governance responsibilities.
- Procedure writing that provides practical guidance for first-line teams, operations, and compliance functions.
- Transaction reporting scenario planning to assess the impact of rule changes, CSSR adoption, and reporting scope revisions.
- Independent thematic reviews that identify data quality weaknesses, control gaps, and potential regulatory risks before they become supervisory findings.
Whether you are assessing the impact of PS26/15 or preparing for implementation, a structured review can help ensure your reporting framework remains robust, efficient, and regulator-ready.
The transaction reporting landscape is changing. Firms that begin planning now will be better placed to reduce costs, improve reporting quality, and meet the FCA’s expectations with confidence.
Contact us today to discuss how your firm can prepare for the PS26/15 transaction reporting reforms.
Frequently Asked Questions
When do the UK MiFIR transaction reporting reforms take effect?
The new UK MiFIR transaction reporting framework comes into force on 3 April 2028.
The FCA has also confirmed that it will adopt a pragmatic supervisory approach from 3 August 2026, giving firms time to update systems, controls, and reporting processes ahead of full implementation.
What are the biggest changes to UK MiFIR transaction reporting?
What should firms do before the new rules take effect?
Firms should begin assessing how the reforms affect reportability rules, transaction reporting systems, policies, procedures, and data quality controls. Early planning will help firms manage implementation more effectively and reduce the risk of remediation work closer to the April 2028 deadline.
Will the reforms reduce compliance costs?
Many firms may benefit from lower reporting volumes and simplified reporting requirements. However, these efficiencies will only be realised if firms invest in updating reporting logic, testing system changes, and strengthening the controls that support transaction reporting data qualit
How can firms assess whether they are ready for the UK MiFIR transaction reporting reforms?
Firms should carry out a structured assessment of their transaction reporting framework, including governance, reportability logic, systems, controls, and data quality. An ARRMA review can help identify gaps, prioritise remediation, and support a smoother transition to the new FCA requirements.