The FCA has signalled the biggest shift in UK transaction reporting since MiFIR was first introduced, setting out plans for a streamlined, more proportionate framework that promises to reduce complexity, cut costs and remove long-standing operational burdens for reporting firms.
The consultation, CP25/32, lands at a moment when the regulator is under pressure to support domestic competitiveness while improving the quality and usefulness of market data, claims ACA Group.
For many firms, transaction reporting has long been viewed as an expensive, resource-heavy obligation with limited tangible benefit. The consultation marks a clear pivot towards a UK-specific regime focused on proportionality and clarity, reinforcing the FCA’s ambition to reduce unnecessary reporting duties while strengthening market integrity and supporting economic growth.
The regulator has emphasised that the reforms are designed not only to simplify processes, but also to enhance its oversight capabilities in areas such as financial crime detection.
Published on 21 November 2025, CP25/32 outlines a comprehensive redesign of the UK MiFIR reporting rulebook. The FCA is proposing a series of adjustments intended to create a leaner, simplified structure better aligned with domestic regulatory priorities. The proposals include significant field removals, updated definitions and technical refinements aimed at reducing day-to-day friction for compliance teams.
The first major change is the deletion of 13 reporting fields considered redundant, including information on option type, maturity date, order transmission and several indicator fields. The concept of a “complex trade” is being replaced with the EMIR-aligned “package transaction”, requiring separate reports for each individual component of a package and the addition of two new fields to support the updated definition. The shift is expected to bring greater consistency across UK reporting regimes.
Another headline reform is the move to restrict reporting obligations to instruments tradeable on UK venues, saving firms an estimated £31.5m per year. This adjustment removes the need to report transactions in around 6m instruments traded solely on EU venues, and effectively ends UK reliance on ESMA’s TOTV opinion.
FX derivatives will also be removed from UK MiFIR reporting, with the FCA confirming that UK EMIR already provides sufficient risk coverage. Further clarifications have been issued for indices, baskets and structured products, while CPMI firms will retain their exemption.
The regulator is also proposing to simplify transmission arrangements under Article 4 by enabling receiving firms to submit transaction reports on behalf of both counterparties, provided relevant information is transferred appropriately. In addition, back-reporting obligations would fall from five to three years, reducing operational strain for firms with high reporting volumes.
The consultation also sets out data and systems enhancements, including confirmation that the FCA’s FIRDS will become the golden source for determining reportability. Instruments executed on a UK venue will automatically fall in scope.
The regulator is reviewing new functionality for FIRDS and exploring improvements to its Market Data Processor as part of an ongoing technology-modernisation strategy. XML will remain the mandatory reporting format, consistent with other major regimes.
A forward-looking component of the consultation focuses on longer-term harmonisation of MiFIR, EMIR and SFTR, with the FCA, HM Treasury and the Bank of England aligning behind three core principles: only collecting necessary data, reporting information once, and sharing data appropriately. While a unified “report once” model is not imminent, the proposal to remove FX derivatives from MiFIR reporting demonstrates the regulator’s move towards eliminating duplication.
Looking ahead, the FCA has outlined several initiatives to support firms through the transition. These include a new transaction reporting user pack in 2026, upcoming guidance on aggregate client account reporting, and the creation of a cross-authority working group to progress a more integrated reporting framework. Final rules are expected in the second half of 2026, followed by an 18-month implementation window.
Firms are encouraged to act now by assessing the potential impact of the proposed changes, updating systems and preparing internal roadmaps. The FCA’s consultation remains open until 20 February 2026.
ACA has warned that inaction carries significant risks. With its Regulatory Reporting Monitoring and Assurance (ARRMA) solution, the firm helps financial institutions address data accuracy, completeness and timeliness across EMIR and MiFIR obligations.
With 93% of submissions reviewed by ACA in 2025 containing at least one error, the company argues that firms must strengthen frameworks early to avoid costly remediation once the rules are finalised. ARRMA offers automated reconciliations, end-to-end oversight and audit-ready feedback, helping firms prepare for a reporting landscape that is set to change dramatically.
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