FCA Transaction Reporting Changes: What PS26/15 Means for Firms
On 3 August 2026, the Financial Conduct Authority (FCA) published Policy Statement PS26/15, Improving the UK transaction reporting regime. It confirms final rules that cut the number of transaction report fields from 65 to 52, take foreign exchange (FX) derivatives and instruments tradeable only on European Union (EU) trading venues out of scope, and shorten the default back reporting period from five years to three. The new regime comes into force on 3 April 2028, but a flexible supervisory approach began on 3 August 2026, so firms that are ready can take part of the benefit now rather than in two years' time.
The changes follow consultation CP25/32, published on 21 November 2025, and sit within HM Treasury's repeal of the assimilated UK Markets in Financial Instruments Regulation (MiFIR) transaction reporting legislation, which allows the FCA to restate the regime in its Handbook. The FCA estimates that firms currently spend £493m a year meeting UK MiFIR transaction reporting requirements, and expects the package to reduce reporting costs by more than £100m annually once implemented.
Which Firms Do the New Transaction Reporting Rules Apply To?
PS26/15 affects investment firms, operators of trading venues, approved reporting mechanisms (ARMs) and other market participants that submit transaction reports, instrument reference data or order book data. The FCA states expressly that the changes are not aimed at consumers, and they do not reach firms with no transaction reporting obligation.
The FCA has introduced a defined term to replace repeated references to permissions in its rules. A transaction reporting firm is either a MiFID investment firm, excluding a collective portfolio management investment (CPMI) firm, or a third country investment firm when it carries on MiFID or equivalent third country business from an establishment in the United Kingdom. Some respondents argued that CPMI firms should be brought within the definition on the basis that more comprehensive data would reduce market abuse risk. The FCA declined, and said it is considering reporting obligations for those firms separately through its Fund Reporting for Asset Management Entities consultation, CP26/26, which closes on 22 September 2026.
The obligation follows the legal entity rather than the group. Asset management groups frequently contain both a CPMI entity and a separately authorised MiFID firm, so establishing which entities are transaction reporting firms is the first piece of work, not an administrative detail to be settled later.
What the FCA Has Confirmed in PS26/15
The FCA received 52 responses to CP25/32 and found support for most proposals. It is proceeding broadly as consulted, with targeted adjustments in a few areas. Everything below is a final rule or final guidance unless stated otherwise. The supporting schema, validation rules and guidelines are not yet available and will be consulted on in October 2026.
A Narrower Reporting Perimeter
The reporting perimeter contracts in three ways. First, scope is limited to financial instruments tradeable on UK trading venues, removing reporting obligations for around 7 million instruments that are only tradeable on EU trading venues. The FCA estimated in CP25/32 that this alone would save firms approximately £31.5m annually. Second, FX derivatives leave the regime entirely, which the FCA says will reduce costs for over 400 UK firms. This covers options, futures, swaps, forward rate agreements and other currency derivative contracts settled physically or in cash, but it expressly does not extend to derivative contracts relating to cryptoassets, which remain reportable. Third, the exclusions from the definition of a transaction have been widened. MAR 14.2.4R(9) now excludes all corporate event activity other than initial public offerings (IPOs), secondary public offerings, placings and debt issuance, and MAR 14.2.4R(6) has been broadened from portfolio compression alone to all eligible post-trade risk reduction services.
Fewer Fields, and Firmer Rules on Populating Them
The reduction from 65 fields to 52 comes from removing information the FCA has concluded is duplicative or of limited supervisory value. Firms should expect to retire the following from their transaction reports:
the transmission of order indicator, which 96% of respondents supported removing;
the SwpIn and SwpOut tags for equity swaps;
option type, option exercise style and delivery type, all derivable from the Classification of Financial Instruments code;
maturity date and notional currency 2; and
the five indicator fields at RTS 22 fields 61 to 65, covering waiver, short selling, over-the-counter post-trade, commodity derivative and securities financing transaction indicators.
Alongside the removals, country of the branch for the buyer and seller is replaced by new Boolean client indicator fields, a package identifier replaces the complex trade component identifier, and a second price field is added so that both leg and package prices can be captured. Eleven fields are also removed from the RTS 23 instrument reference data set, together with currency of nominal value, which the FCA concluded can be derived from notional currency 1.
FCA FIRDS Becomes the Golden Source
Firms may now rely exclusively on the FCA Financial Instrument Reference Data System (FIRDS) to determine whether a transaction is reportable, with instruments executed on a UK trading venue automatically in scope. The obligation to make that determination is limited to T+7. If the instrument or its underlying is not in FCA FIRDS by that point, there is no obligation to report. The FCA has also confirmed it will not take action where a firm reasonably concludes an instrument is in scope, submits a report and has it rejected, which addresses pre-admission trading.
This is a meaningful reduction in due diligence effort. Nearly 12 million active over-the-counter International Securities Identification Numbers sit in FCA FIRDS, accounting for 66% of all active financial instruments on the system. What remains unresolved is timing: the FCA is considering whether to stop ingesting EU instrument reference data into FCA FIRDS before April 2028 and has promised an update in October 2026. Firms that do not take advantage of the supervisory flexibility could see rejections if that change lands first.
A Three-Year Default Back Reporting Period
The reduction from five years to three is a change to supervisory expectation rather than a rule, and it applies immediately from 3 August 2026. The FCA has made the expectation explicit in new guidance at MAR 14.15.4G. Two qualifications matter. The FCA retains the ability to require up to five years of back reports on an exceptional basis for serious reporting failings, and it will use Market Watch to give transparency on the volume and nature of those requests. Separately, record keeping obligations are untouched: firms must still retain transaction and order records for five years under the Conduct of Business Sourcebook (COBS) 11 and Senior Management Arrangements, Systems and Controls (SYSC) 9.
The FCA has confirmed the new reporting schema will be backwards compatible, with trade date determining whether new or historical validation rules apply to a report. It has decided against introducing an amend function for correcting historical errors, concluding the implementation cost would outweigh the benefit, though it may revisit this.
Conditional Single-Sided Reporting Proceeds Despite Opposition
This is the one area where the FCA has pressed ahead against the weight of feedback. Most respondents considered the proposed Conditional Single-Sided Reporting (CSSR) model unworkable, arguing it shifts operational risk from buy-side to sell-side firms and still requires sensitive data exchange, contractual arrangements and reconciliation controls. Several pressed instead for unconditional single-sided reporting or an exemption for buy-side firms.
The FCA has confirmed it will proceed. It reduces the information points a sending firm must provide from ten to four and extends CSSR to firms acting in DEAL and MTCH trading capacities. Its response is direct: CSSR was never intended to relieve buy-side firms of reporting, because buy-side data is critical to monitoring market functioning and financial stability. The FCA notes that 92% of transaction reports submitted in 2025 contained no personally identifiable information in the buyer, seller or decision maker fields, and that take-up is optional. Uptake has been low historically, with only 138 firms acting as a receiving firm in 2025, down from 164 in 2024, and the FCA did not include any CSSR savings in its cost benefit analysis.
Lighter Requirements for Trading Venues
Trading venues will no longer need to populate the investment decision within firm and execution within firm fields where the decision maker is a natural person, using a new NPEX code instead. The FCA says this simplifies the information provided by over 2,200 international firms when accessing UK financial markets. Existing requirements continue where the decision was made primarily by an algorithm. The concept of admission to trading is extended to multilateral trading facilities undertaking primary market activities, systematic internalisers no longer submit instrument reference data, and venues need only submit instrument reference data on the first reportable event and on subsequent changes. References to Central European Time become Coordinated Universal Time, and the FCA has corrected a drafting error in MAR 15.4.1 to preserve the existing 20:00 UTC submission deadline.
New Guidance on Managing Reporting Errors
In response to requests for clarity on systems and controls, the FCA has added guidance at MAR 14.15.5G. Transaction reporting firms and operators of qualifying trading venues should maintain an incident management framework, proportionate to the nature, scale and complexity of the business, that enables them to triage and assess errors and omissions, analyse root causes, implement and monitor remediation, operate an internal escalation protocol and notify the FCA. The guidance aligns with observations in Market Watch 81 and 82. The FCA has decided against introducing a materiality threshold for breach notifications at this stage.
What Did the FCA Change or Not Take Forward?
Several consulted proposals did not survive in their original form, and firms working from CP25/32 should note the differences. The FCA dropped its proposal to report the segment Market Identifier Code where a counterparty is unknown at execution, and has instead codified existing practice of using the central counterparty Legal Entity Identifier (LEI). It removed MAR 14.13.32R(3) on the distinction between MTCH and AOTC trading capacities, while making paragraphs (1) and (2) as final rules. On trusts, it tightened rather than relaxed: MAR 14.13.10G(2) now requires a trust LEI where one already exists, with beneficiary identification available only where no LEI exists. It also declined to adopt the Unique Product Identifier for over-the-counter derivatives, to publish a prescribed list of reportable indices, and to mandate a standard format for trading venue transaction identification codes, noting that matching rates improved from 83% in a Q2 2025 sample to 87% in a Q2 2026 sample.
Key Themes
Four broader messages run through the Policy Statement.
Simplification is being delivered incrementally, not through wholesale redesign. The FCA and the Bank of England have established a Transaction and Post-trade Reporting Industry Harmonisation Taskforce, which held its inaugural meeting in July 2026 and operates through three working groups covering policy, strategy and architecture. Work to repeal and replace over-the-counter derivative reporting under Title II of UK European Market Infrastructure Regulation (EMIR) is running alongside. Firms should treat the 2028 regime as a staging post rather than an end state.
Data quality expectations are not being relaxed. Several changes, including the client indicator fields and the trading capacity consistency rules, exist because the FCA has seen persistent inconsistency. Fewer fields means each remaining field carries more weight.
Cost relief is available early but is conditional. The supervisory flexibility runs from 3 August 2026, yet several changes depend on validation rules the FCA will not amend until October 2026.
Scope determination has become the principal control. With FCA FIRDS designated as the golden source and a T+7 cut-off, the quality of a firm's scoping logic largely determines the quality of its reporting.
What Should Firms Do Now
The FCA's own guidance is to begin planning now, reviewing reporting logic, considering the impact of scope and field changes, and preparing for the revised schema and validation rules. For most affected firms this is a scoped reporting change project rather than a framework overhaul. The sequencing matters more than the speed.
A proportionate approach would cover the following:
Confirm which legal entities in the group are transaction reporting firms under the new definition, and document the conclusion, particularly where CPMI entities are involved.
Map current trading flows against the revised perimeter to identify what falls out of scope, what remains reportable, and where field population or supporting rationale must change.
Decide, entity by entity, whether to adopt the supervisory flexibilities early. This is a governance decision with a rejection risk attached, not a purely operational one, and the position should be revisited after the October 2026 consultation.
Apply the reduced three-year back reporting expectation to any live remediation, since it takes effect immediately.
Review the incident management framework against MAR 14.15.5G, covering triage, root cause analysis, remediation tracking, escalation and FCA notification.
Allocate implementation ownership to a named Senior Manager and reflect it in the Statement of Responsibilities where the change is material to the firm.
Update compliance monitoring so that testing follows the revised field set rather than the current one, and refresh management information to give the board visibility of rejection rates and error volumes through the transition.
Engage ARMs, vendors and trading venues early on their implementation timetables, since much of the operational dependency sits outside the firm.
In our experience, the risk in a change of this kind is not the technical build but the decisions taken along the way. Firms that record why an instrument population was treated as out of scope, or why an early adoption was deferred, are in a far stronger position when the FCA asks about reporting quality two years later than firms that simply implemented and moved on.
Frequently Asked Questions
When do the new FCA transaction reporting rules come into force?
The new regime comes into force on 3 April 2028. The FCA is applying a flexible supervisory approach from 3 August 2026 until that date, covering specified areas set out in Chapter 6 of PS26/15, so firms that are ready can implement some changes early. The reduced three-year default back reporting period applies immediately from 3 August 2026.
Does PS26/15 apply to asset managers?
Not directly in most cases. A transaction reporting firm is a MiFID investment firm excluding a collective portfolio management investment firm, or a third country investment firm carrying on MiFID or equivalent business from a UK establishment. Many asset managers therefore fall outside the definition, and the FCA is considering their reporting obligations separately through CP26/26. Groups containing a separately authorised MiFID entity should check that entity's position.
Are FX derivatives still reportable under UK MiFIR?
FX derivatives are removed from the scope of the transaction reporting regime under the final rules. During the implementation period the FCA will not take action against firms that stop reporting them, provided those firms submit UK EMIR data for the same transactions. Firms not subject to UK EMIR reporting, including UK branches of third country firms, must continue to meet applicable requirements. Derivative contracts relating to cryptoassets are not covered by this removal and remain in scope.
How long must firms now back report transaction reporting errors?
The default expectation is three years, reduced from five. The FCA can still require up to five years on an exceptional basis where reporting failings are serious enough to affect market abuse investigations or market monitoring. Record keeping obligations are unchanged: transaction and order records must still be retained for five years under COBS 11 and SYSC 9.
Should firms implement the changes now or wait until 2028?
That is a firm-specific judgement. Early adoption releases cost savings sooner, but several changes depend on validation rule amendments the FCA will make following its October 2026 consultation. Implementing ahead of those amendments can generate transaction report rejections. Firms should take a documented decision per change area rather than a single blanket position.
How Compliance Angle Can Help
Compliance Angle supports FCA-regulated firms in translating regulatory change into practical implementation. On PS26/15 specifically, that support typically covers:
scoping and applicability assessments, establishing which entities are transaction reporting firms and which flows remain in scope;
gap analysis against the revised field set, rules and guidance, with a prioritised implementation plan;
policy and procedure development, including reporting policies and incident management and breach notification procedures aligned to MAR 14.15.5G;
compliance monitoring programme updates so that testing reflects the new requirements;
governance and Senior Managers and Certification Regime support, including allocating implementation responsibility and updating Statements of Responsibilities; and
board and Senior Manager advisory support and ongoing compliance resource through the transition.
Our support is proportionate to the firm's business model, permissions, size and regulatory risk. A firm executing on two UK venues does not need the same programme as a cross-border broker with multiple booking models, and we scope the work accordingly.
To discuss how PS26/15 affects your firm, contact us at info@complianceangle.co.uk.
Source: Financial Conduct Authority, Policy Statement PS26/15, Improving the UK transaction reporting regime, published 3 August 2026. Available at fca.org.uk.
