FCA Transaction Reporting Regime: What CP26/34 Means for Firms Preparing for April 2028
The FCA's new transaction reporting rules are already final and take effect on 3 April 2028; CP26/34 does not reopen them. Instead, the Financial Conduct Authority (FCA) is consulting on how those rules should work in practice: draft guidance and worked examples for a new Transaction Reporting User Pack, transitional guidance for the switchover from UK MiFIR, and consequential Handbook amendments. The consultation was published on 2 October 2026 and closes on 6 November 2026.
The proposals are relevant to investment firms with transaction reporting obligations, operators of trading venues, approved reporting mechanisms (ARMs) and other firms submitting transaction reports, instrument reference data or order book data. Firms that do not execute or transmit orders in reportable financial instruments, including most consumer credit, payments and e-money businesses, are not affected. For firms in scope, CP26/34 is the clearest indication so far of how the FCA expects the new FCA transaction reporting regime to be applied.
What Is the FCA Consulting On in CP26/34?
HM Treasury plans to repeal the transaction reporting provisions of the UK Markets in Financial Instruments Regulation (UK MiFIR). In PS26/15, the FCA made replacement rules in three new Market Conduct sourcebook chapters: MAR 13 (order record keeping), MAR 14 (transaction reporting) and MAR 15 (financial instrument reference data). The FCA has said these rules reduce reporting fields from 65 to 52 and will save firms more than £100 million a year (FCA press release, 3 August 2026). Alongside CP26/34, it has published draft schema and validation rules on the Market Data Processor (MDP) webpage.
There are four strands to the consultation:
Draft guidance and worked examples in seven areas changed by PS26/15, which will form part of the new Transaction Reporting User Pack.
The approach to carrying relevant ESMA Level 3 materials into that User Pack.
A new transitional chapter, MAR TP 5, covering the switchover from UK MiFIR.
Consequential amendments to the Glossary, COBS, MAR, REC, SYSC and related Technical Standards.
Because the guidance clarifies rules already made rather than adding obligations, the FCA has not produced a cost benefit analysis. It remains proposed guidance, however, and may change before it is finalised.
The Main Proposals
A Single Transaction Reporting User Pack
From 3 April 2028, the User Pack will replace the ESMA transaction reporting guidelines, the ESMA Q&A on MiFIR data reporting and the ESMA opinion on traded on a trading venue (TOTV). Until then, firms should continue to have regard to those materials. The FCA will consult on the full User Pack in Q1 2027 and publish it by 3 April 2027. The sections of the ESMA Guidelines on branches, swaps and complex trades will not be carried across, because PS26/15 changed the underlying policy.
Branch Execution
Consistent with Market Watch 70, the FCA says firms should not decide whether a transaction is executed through a UK branch solely by reference to where a trader is physically located. Firms should instead apply the factors in MAR 14.13.26R to MAR 14.13.32G, including which branch received the order, which branch supervises the investment and execution decision makers, and whose membership was used. A trader temporarily in London but supervised from, and booking to, New York would generally not create a UK reporting obligation on that basis alone.
The practical point is evidential. Firms are expected to document which entity and branch retain supervisory, mandate and trading oversight responsibility, and to be able to demonstrate how reporting decisions were reached.
Conditional Single-Sided Reporting
Conditional single-sided reporting (CSSR) is an optional framework under which one transaction reporting firm reports for both. The conditions include a pre-existing written agreement specifying at least the time limit for the sending firm to provide the information in MAR 14.10.2R. The receiving firm completes the remaining fields from its own execution data. Whether the sending firm or its clients are reported as buyer or seller depends on the sending firm's trading capacity, and the sending firm must supply client allocation quantities.
Field-Level Clarifications
The remaining examples address how specific MAR 14 fields should be populated:
Client indicator (Fields 8 and 17): these replace the "country of the branch" fields and are assessed from the executing entity's perspective.
Meaning of a transaction for derivatives: acquisitions and disposals are judged by changes in economic exposure, with examples covering increases and decreases in notional and early terminations.
Equity swaps: Field 31 (Price) should carry the reference price of the direct underlying, not the financing spread. The FCA is seeking views where both legs comprise equity instruments.
Strike price: "NOAP" should be reported in Field 48 where the strike price cannot be determined at execution.
Package transactions: these replace "complex trades", need not have a single price or simultaneous execution, and are linked by a package identifier in Field 37.
How Will the Switchover on 3 April 2028 Work?
FCA systems will move to the new schema at 00:00 UTC on 3 April 2028, after which UK MiFIR format reports will not be accepted. The proposed MAR TP 5 covers obligations arising before that point but discharged after it:
Transactions executed between 00:00:00 UTC on 31 March 2028 and 23:59:59 UTC on 2 April 2028 may be reported in the UK MiFIR format before 3 April 2028, or afterwards in the MAR 14 format, which the FCA will treat as compliant.
Records from before 3 April 2028 need not be reformatted into the MAR 13 format.
Corrections and late submissions made after 3 April 2028 should use the MAR 14 and MAR 15 formats, even for earlier transactions, although firms need not add information that was not originally required.
Trading venues follow similar principles for instrument reference data. MAR TP 5 is drafted entirely as guidance rather than rules, and its commencement date has not yet been set. In our view, firms will need the capability to resubmit historic transactions in the new format for some time after implementation, and this should be reflected in system design and back-reporting procedures.
Consequential Amendments and EU-Only Instruments
Most consequential amendments update cross-references, and the FCA does not expect firms to change anything in response. The exception is removal of the short selling flag from the record-keeping details in COBS 11.5A.3R and from high-frequency algorithmic trading records. Separately, the FCA is considering removing instruments tradeable only on EU trading venues from its Financial Instrument Reference Data System (FIRDS) before 3 April 2028. That depends on HM Treasury amending the legislation and has not been decided.
Key Themes From the Consultation
First, the rules are settled and the open questions concern interpretation: the FCA accepts that the Level 3 materials do not cover every scenario and is asking firms to identify gaps. Second, evidence matters. The guidance emphasises consistent field population and demonstrable reporting decisions, and after go-live the FCA expects to monitor rejection rates, validation errors, corrections and field completeness. Senior management remain responsible for systems and controls over reporting.
What Should Firms Do Now
For most firms in scope, a structured review against the draft guidance will be more useful than reopening the whole implementation programme. Proportionate starting points include:
Confirming applicability, including whether the firm executes or transmits reportable transactions, relies on an ARM or intends to use CSSR.
Carrying out a gap analysis of reporting logic against the seven areas of draft guidance.
Documenting branch attribution for each desk, including for staff working away from their usual location.
Agreeing written CSSR arrangements with counterparties, with time limits, and testing information flows.
Planning for the transition window and for correcting historic reports in the new format.
Confirming the accountable Senior Manager, implementation management information and board reporting.
Extending compliance monitoring to cover reconciliations and data quality from go-live.
Recording interpretations while guidance is draft, and considering a response by 6 November 2026.
Firms that report through an ARM are unlikely to need extensive work, but should confirm what their provider is doing and retain oversight of the outcome.
Frequently Asked Questions
When does the new FCA transaction reporting regime take effect?
The new regime takes effect at 00:00 UTC on 3 April 2028, when MAR 13, MAR 14 and MAR 15 replace the UK MiFIR transaction reporting, record keeping and reference data requirements. From that point, FCA systems will only accept reports in the new format.
Is CP26/34 consulting on new transaction reporting rules?
No. The rules were finalised in PS26/15. CP26/34 consults on guidance for a new Transaction Reporting User Pack, transitional guidance in MAR TP 5 and consequential Handbook amendments. Responses are due by 6 November 2026.
Which firms are affected by CP26/34?
CP26/34 affects investment firms with UK transaction reporting obligations, operators of trading venues, approved reporting mechanisms and other firms submitting transaction reports, instrument reference data or order book data. Firms that do not execute or transmit orders in reportable financial instruments are not affected.
Can firms still rely on the ESMA transaction reporting guidelines?
Yes, until 3 April 2028. Firms should continue to have regard to the existing Level 3 materials until then, when the FCA's Transaction Reporting User Pack replaces them. The final User Pack is due by 3 April 2027.
How should firms correct pre-2028 transaction reports after 3 April 2028?
Under the FCA's draft transitional guidance, corrections made after 3 April 2028 should use the MAR 14 and MAR 15 formats, even for transactions originally reported under UK MiFIR. Firms are not expected to add information that was not required at execution. This is a proposal and may change.
How Compliance Angle Can Help
Compliance Angle supports investment firms preparing for regulatory change, with practical advice proportionate to each firm's business model, permissions, size and regulatory risk. For the new transaction reporting regime, the most relevant services are:
regulatory change implementation, covering planning and oversight of the move to the new rules;
compliance gap analyses and regulatory health checks against the new rules and draft guidance;
governance and SM&CR support, including accountability for reporting and documentation of branch attribution;
policy and procedure development for transaction reporting, CSSR and corrections;
compliance monitoring frameworks, including assurance over reporting quality; and
Board and Senior Manager advisory support on implementation oversight.
If you would like to discuss how CP26/34 affects your firm, please contact us at info@complianceangle.co.uk.
Source: Financial Conduct Authority (FCA), CP26/34: Preparing for the new transaction reporting regime, published 2 October 2026: CP26/34 consultation page
