UK FCA consults on improving the UK transaction reporting regime

The UK Financial Conduct Authority (FCA) has published consultation paper CP25/32 setting out proposals to improve the UK transaction reporting regime under the Markets in Financial Instruments Regulation (MiFIR). HM Treasury previously confirmed that assimilated law (law inherited from the EU at the point of Brexit) in this area will be repealed, enabling the FCA to deliver a more streamlined framework aimed at reducing the regulatory burden on firms and increasing the FCA's ability to fight financial crime and protect market integrity. In particular, the FCA is looking to replace the regulatory technical standards in Commission Delegated Regulations (EU) 2017/590 (RTS 22), 2017/585 (RTS 23), and 2017/580 (RTS 24) with new rules in its Market Conduct Sourcebook (MAR). Key proposals are set out below.

In particular:

• Reducing the number of transaction reporting fields from 65 to 52.
• Removing reporting obligations for 6 million financial instruments tradeable only on EU trading venues.
• Excluding foreign exchange derivatives from the scope of reporting requirements.
• Shortening the default back reporting period from five to three 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.
• Reducing the number of instrument reference data fields from 48 to 37.
• Removing the obligation on systematic internalisers to submit instrument reference data.

The FCA also proposes to provide additional clarity about specific reporting requirements to improve reporting efficiencies, cut costs and support better data quality. The deadline for comments is 20 February 2026. Final rules are expected in H2 2026, alongside confirmation of the implementation period which the FCA expects to be around 18 months. The FCA also intends to establish a cross-authority and industry working group on its approach to transaction reporting. It will provide more information on the group's terms of reference and the application process in Q1 2026.

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