UK FCA final rules on improving the UK transaction reporting regime

The UK Financial Conduct Authority (FCA) has published policy statement PS26/15, which sets out final reforms to improve the UK transaction reporting regime under the Markets in Financial Instruments Regulation (MiFIR). This follows the November consultation and HM Treasury previously confirming that assimilated law (law inherited from the EU at the point of Brexit) in this area will be repealed, enabling the FCA to deliver a more streamlined framework. The FCA has largely finalised the proposals as consulted on, with a few targeted adjustments.

Key changes to the regime include:

• Reducing the number of transaction reporting fields from 65 to 52.
• Removing reporting obligations for seven million financial instruments which are only tradeable on EU trading venues (up from the figure of six million initially consulted on).
• Removing foreign exchange (FX) derivatives from the scope of reporting requirements.
• Reducing the default back reporting period from five to three years.
• Exempting most corporate actions from reporting obligations.
• Requiring trading venues to populate fewer fields in their transaction reports.
• Creating a new framework for conditional single-sided reporting.

The final rules are set out in the Markets in Financial Instruments (Record Keeping, Transaction Reporting and Financial Instrument Reference Data) Instrument 2026, which introduces three new chapters in the FCA's Market Conduct sourcebook. Firms will have until 3 April 2028 to implement the changes. The FCA intends to publish draft schemas, validation rules and updated reporting guidance, which will form part of a new transaction reporting user pack, in October this year and will adopt a flexible supervisory approach during the implementation period. It also plans to consult on transitional provisions and consequential amendments to the FCA Handbook. The FCA states that affected firms should begin planning now by reviewing their reporting logic, assessing the impact of changes to reporting scope and data fields, and preparing for the revised schema, validation rules and guidance.

In addition to the above, chapter 2 of the policy statement sets out the FCA's longer-term ambition to harmonise transaction and post-trade reporting requirements across the UK MiFIR, UK European Market Infrastructure Regulation (EMIR) and Securities Financing Transactions Regulation (SFTR) regimes.

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