The Financial Conduct Authority (FCA) has released consultation paper CP26/34, Preparing for the New Transaction Reporting Regime, a further move towards replacing the existing UK MiFIR transaction reporting framework. Firms that treat the 3 April 2028 go-live date as a distant concern risk falling behind on the operational and data work it demands.
According to ACA Group, the headline policy changes were settled in PS26/15. This latest paper looks at how firms should get ready for implementation and manage the transition.
Responses are due by 6 November 2026. The paper sets out proposed guidance, technical standards, validation rules and transitional arrangements, all of which will shape how firms build towards compliance.
The regulator has also said it will consult on a new Transaction Reporting User Pack (TRUP) in Q1 2027, with the final version due by 3 April 2027. That gives firms another chance to clarify supervisory expectations well before the regime goes live.
Data quality remains the priority. The FCA regards transaction reports as a vital input for market monitoring, market abuse surveillance and wider supervision. The new framework is designed to simplify reporting and remove unnecessary complexity, but firms will still be expected to submit reports that are accurate, complete and consistent.
CP26/34 centres on consistent application of the rules. It proposes guidance on key parts of the new framework, transitional provisions for moving away from the current regime, and consequential amendments to Handbook rules and technical standards. It also proposes a new TRUP that brings reporting guidance, instrument reference data guidance and worked examples together in one place.
The timetable is staggered. The consultation closes on 6 November 2026, the TRUP consultation follows in Q1 2027, the final TRUP is published on 3 April 2027, and the regime takes effect on 3 April 2028. By the time the final TRUP arrives, firms should already be well into gap analysis, operating model design and technology planning.
The FCA has already published draft schema and validation rules, so impact assessments can start now. A structured review should cover how the rules affect existing processes and controls, and should map current reporting fields against the proposed schema to find data gaps. It should also test whether platforms and workflows can support the future model, and check ownership, escalation, exception management and reconciliation. Compliance, operations, technology, front office and reporting teams should work together through a coordinated programme.
Firms that outsource their reporting are not excused. Accountability for accuracy, completeness and timeliness stays with them.
This is not just a technology project. Meeting the FCA’s consistency goal will require clear governance, documented reporting decisions, thorough testing and continuing oversight of reporting quality. Firms that use each milestone well can expect fewer surprises, lower implementation risk and a smoother transition in April 2028.
Read the full ACA Group post here.
Copyright © 2026 RegTech Analyst
Copyright © 2026 RegTech Analyst
