FCA Finalises Overhaul of UK Transaction Reporting

On 3 August 2026, the Financial Conduct Authority (FCA) published Policy Statement PS26/15, setting out final transaction reporting rules that will replace and restate assimilated EU law derived from the Markets in Financial Instruments Regulation (UK MiFIR). The policy statement follows HM Treasury’s decision to repeal the existing UK MiFIR transaction reporting legislation, enabling the FCA to deliver a purpose-built domestic framework. As we noted in our earlier article on the FCA’s November 2025 consultation (CP25/32), this reform programme is designed to simplify reporting obligations, reduce duplicative data collection and improve market integrity, while supporting the competitiveness and growth of UK capital markets.

Key Changes

Having received broad support from those commenting on or responding to CP25/32, the FCA is proceeding with most proposals as consulted, subject to targeted adjustments. The principal changes include the following:

• Scope reduction: Reporting fields will be cut from 65 to 52. Around seven million instruments tradeable only on EU venues will be removed from scope, with reportability limited to UK trading venues.
• FX derivatives excluded: Currency options, futures, swaps, forward rate agreements and any other derivative contracts relating to currencies which may be settled physically or in cash will be removed from the scope of transaction reporting, with the FCA relying on UK European Market Infrastructure Regulation (EMIR) data instead. Cryptoasset derivatives will remain in scope.
• Error correction: The default back reporting period will be reduced from five to three years (lowering resubmission volumes by roughly a third), though the FCA will retain discretion to require up to five years data to be resubmitted in exceptional cases.
• Corporate actions: Most corporate actions will be exempted (IPOs, placings and debt issuance will remain reportable).
• Conditional Single-Sided Reporting: A new framework for optional Conditional Single-Sided Reporting should reduce data points transmitted by sending firms from ten to four.
• FCA FIRDS as golden source: The FCA’s Financial Instrument Reference Data System will become the definitive source for determining reportability. This will be subject to a T+7 obligation, whereby if an instrument (or its underlying) is not in FCA FIRDS by T+7, there will be no obligation to report. 

Implementation Timeline

The new regime will come into force on 3 April 2028, following an eighteen-month implementation period. The FCA is adopting a flexible supervisory approach from 3 August 2026, so firms that are ready may benefit from certain measures immediately. For instance, the FCA has stated that it will not take action against firms that do not report transactions in financial instruments which are only tradeable on EU trading venues. The FCA will also not take action against firms that do not report transactions in FX derivatives, provided such firms are subject to UK EMIR reporting requirements for such instruments.

In October 2026, the FCA intends to publish a draft schema, validation rules and updated guidelines (forming a new Transaction Reporting User Pack), together with transitional provisions.

Looking Ahead

Firms may look to use the intervening period to assess the impact of scope and data-field changes on their reporting logic, review data governance and control frameworks, and prepare for the revised schema and validation rules expected later this year. The FCA’s establishment of a joint reporting harmonisation taskforce with the Bank of England signals a longer-term ambition to align reporting across UK MiFIR, EMIR and the Securities Financing Transactions Regulations.

PS26/15 can be found here.