FCA Proposes Overhaul of the UK Transaction Reporting Regime: What Firms Need to Know

On 21 November 2025, the Financial Conduct Authority (FCA) issued CP25/32 – Improving the UK Transaction Reporting Regime, marking the most significant review of MiFIR transaction reporting since its original 2018 introduction and UK onshoring in 2020.

The proposals aim to simplify reporting, cut industry costs, and improve data quality, while setting out a long-term reform agenda in collaboration with HM Treasury and the Bank of England.

The consultation is now open, with responses due 20 February 2026.

Below, we break down the key points; what is changing, why it matters, and what firms should begin preparing for.

Background: Why the FCA is Reforming the Regime

The UK MiFIR transaction reporting framework has become increasingly costly and complex. According to CP25/32, industry currently spends £493 million annually complying with transaction reporting requirements.

The FCA now believes there are significant opportunities to:

• Remove unnecessary fields

• Eliminate duplicative reporting

• Improve data accuracy and completeness

• Reduce costs for firms by over £100 million per year

CP25/32 also outlines a cross-authority long-term vision to streamline reporting across MiFIR, EMIR, and SFTR, tackling issues such as duplicative reporting, inconsistent definitions, and overlapping scopes.

Key FCA Proposals at a Glance

The FCA is consulting on several headline changes, many of which will be welcomed by reporting teams across the market.

Reducing the Number of Transactions Reporting Fields: 65 to 52

The FCA concludes that several fields add limited regulatory value relative to the burden of collecting and maintaining them. This aligns with the FCA’s broader goal of proportionate and smarter regulation.

Removing Reporting Obligations for 6 million EU-Only Instruments

Currently, UK firms must report transactions in instruments tradeable on EU venues, even though the EU does not reciprocate. The FCA proposes limiting scope to instruments tradeable only on UK venues, saving firms an estimated £31.5m annually.

Removing FX Derivatives from the Reporting Regime

More than 400 UK firms would see a material reduction in reporting volume and complexity. This change would also eliminate challenging TOTV-equivalence assessments that have long been an operational burden.

Shortening the Back-Reporting Period: 5 Years to 3 Years

Back-reporting accounts for 9% of all reports the FCA receives.

By analysing 2024 data, the FCA found that 215 million back-reports related to trades older than three years, representing low marginal regulatory value.

The revised requirement:

• Default back-reporting: 3 years;

• FCA retains power to request up to 5 years in serious cases.

This alone is expected to save firms £11.9m per year.

Reducing Trading Venue Reporting Fields

Trading venues will have fewer reporting fields to populate, simplifying requirements for more than 1,700 international firms accessing UK markets.

Streamlining Instrument Reference Data

The obligation for systematic internalisers to submit reference data will also be removed. SIs currently submit over one-third of all reference data received by the FCA.

Conditional Single-Sided Reporting Expanded

One of the most impactful operational proposals is expanding and simplifying conditional single-sided reporting:

• It will no longer be limited to reception-and-transmission scenarios.

• It will apply across all trading capacities, including DEAL and matched principal (MTCH).

• Data firms must transmit will reduce from 10 required fields to just 4.

This change enables buy-side firms, who have pushed hard for relief, to reduce reporting volumes without sacrificing regulatory visibility.

Clearer Rules on Corporate Actions and Fractional Shares

The FCA will:

• Exclude corporate actions from reporting as standard (with optional reporting if easier operationally)

• Clarify that fractional instruments are in scope and must be reported proportionately.

A New Long-Term Reporting Vision Across MiFIR, EMIR & SFTR

CP25/32 confirms a gradual, multi-year reform plan, centred around three principles:

1. Data only collected where needed

2. Firms should only report data once

3. Data should be shared where appropriate

An industry working group with the FCA, Bank of England, and Treasury will be formed in Q1 2026.

Key FCA Proposals at a Glance

Despite strong buy-side calls for exemption, the FCA sets out a clear rationale for continuing buy-side reporting, noting that eliminating it would cause the regulator to lose sight of:

• 56% of buy-side transactions

• 20–30% of sterling corporate bond volumes (up to 40–50% for certain strategies)

• Critical activity during market stress, such as the 2022 gilt dysfunction

This is one of the clearest statements yet of how vital buy-side data is to UK market stability frameworks.

Long-Term Implementation Timeline

According to the consultation:

• Responses due: 20 February 2026

• Policy Statement: Second half of 2026

• Implementation period: Approx. 18 months

If confirmed, firms would be looking at early–mid 2028 for full implementation.

What Firms Should Do Now

Assess your reporting architecture

The potential removal of fields, instruments, and entire asset classes (FX derivatives) may significantly alter reporting flows.

Review buy-side/sell-side data sharing

Expanded conditional single-sided reporting may require revisiting:

• client agreements

• transmission templates

• RTO / execution arrangements

Prepare for dual operating models during transition

Until the new MAR-based regime is finalised, firms will still need to comply with existing RTS rules.

Monitor future EMIR & SFTR consultations

The FCA signals this is only step one. Further consultations across wholesale reporting are expected in 2026–2027.

Final Thoughts

CP25/32 represents a substantial and long-awaited modernisation of the UK transaction reporting regime.

If implemented, it could deliver:

• Significant cost savings

• Greater clarity in reporting requirements

• Better data quality

• Improved market oversight

• A more proportionate long-term reporting framework

For many firms, particularly smaller firms, buy-side firms, and those active only in UK markets, the reforms will likely be transformative.

Compliance Angle will continue to monitor developments and provide analysis as the FCA moves toward finalising the new regime.

Contact Us

Contact Compliance Angle at info@complianceangle.co.uk or call +44 7427 792594 to schedule a free consultation and ensure your firm stays aligned, efficient and ready for the next phase of UK regulatory reform.