Improving UK Transaction Reporting: FCA Consults on Streamlined Framework

On 21 November 2025, the Financial Conduct Authority (FCA) published a consultation paper (CP25/32) setting out proposed reforms to the UK transaction reporting regime (the Regime). The consultation aims to reduce regulatory burdens, improve data quality, and enhance efficiency for UK financial market participants, including investment firms, trading venues, systematic internalisers, trade repositories, and other regulated entities. 

Background 

The Regime, originally derived from the EU Markets in Financial Instruments Regulation (MiFIR), has been in force since 2018 and was onshored into UK legislation following Brexit. HM Treasury (HMT) has indicated its intention to repeal these rules, enabling the FCA to deliver a streamlined framework tailored to UK market needs. The FCA’s proposals follow engagement with market participants, including a 2024 discussion paper (DP24/2), and are informed by feedback highlighting the need to reduce duplicative and disproportionate reporting requirements. 

Key Proposals 

The FCA’s proposed changes include three main areas: the shape of the Regime, the scope of reporting obligations, and the content of transaction reports.

1. Shape of the Regime

• The default period for back reporting (resubmission of corrected reports) would be reduced from five to three years, with the option for the FCA to require up to five years where necessary.
• Most corporate actions would be exempted from transaction reporting, except for IPOs, secondary offerings, placings, and debt issuance. Firms may continue to report corporate actions voluntarily if preferable for operational reasons.
• The FCA proposes to consolidate existing EU guidelines and provide a new transaction reporting user pack, including additional examples and best practice guidance.
• The FCA would maintain ISO 20022 XML as the required messaging standard for transaction reporting whilst also seeking alignment with global data standards, including internationally agreed data definitions from the International Organisation of Securities Commissions (IOSCO), to facilitate efficient data sharing and reduce compliance costs for cross-border firms.

2. Scope of the Regime

• The FCA wants to enable more use of the conditional single-sided reporting mechanism, allowing a receiving firm (typically the sell-side firm, e.g. a broker) to report on behalf of another firm that has transmitted specific details, with the aim of reducing the reporting burden for buy-side firms. The volume of information required to be transmitted would be reduced from ten to four data points.
• Reporting obligations would be limited to financial instruments tradeable on UK trading venues only, removing requirements for over six million instruments tradeable solely on EU venues.
• FX derivatives would be removed from the scope of transaction reporting, with reliance placed on UK European Market Infrastructure Regulation (EMIR) data instead.
• The FCA would not introduce an opt-in register for receiving firms but would instead update the transmission mechanism to support smaller firms in reducing reporting burdens.
• Trading venues would be required to report fewer fields under Article 26(5) of UK MiFIR, particularly removing the requirement to report natural person investment and execution decision maker details, which has been identified as a barrier to market participation and a source of frequent errors.

3. Content of Transaction Reports

• Several reporting fields would be removed or clarified, including the derivative notional increase/decrease field, option type, exercise style, delivery type, and others. The overall number would reduce from 65 to 52 reporting fields.
• The FCA also proposes to reduce the number of instrument reference data fields from 48 to 37.

Implementation and Next Steps 

The consultation period for CP25/32 runs until 20 February 2026. The FCA intends to publish a Policy Statement finalising the new transaction reporting rules in the second half of 2026, with an expected implementation period of around 18 months. Further consultations will be held on transitional provisions and consequential amendments to the FCA Handbook. The FCA will also establish a cross-authority and industry working group to inform the design of its long-term approach to harmonising transaction and post-trade reporting regimes. 

CP25/32 and DP24/2 are available here and here, respectively.