The FCA has finalised its biggest shake-up of UK MiFIR transaction reporting since Brexit, and firms hoping for a straightforward compliance breather may be disappointed. Policy Statement 26/15 strips back reporting complexity, scraps data fields of limited supervisory use, and narrows the pool of reportable instruments.
According to ACA Group, the new regime takes effect on 3 April 2028, with supervisory flexibility beginning 3 August 2026, and applies to UK and international firms under UK MiFIR obligations, alongside their heads of compliance, CCOs, COOs and reporting teams.
ACA Group recently jumped into the development of how UK transaction reporting has got a major reset.
On the surface, this looks like deregulation. In practice, it is a reprioritisation. The FCA is removing requirements that add little to market surveillance while raising the bar on the accuracy and reliability of the data firms still submit. For compliance and operations teams, the message is clear: success will be measured by the strength of controls, not the volume of reports filed.
Scope is shrinking sharply. Transaction reporting will now be limited to instruments traded on UK venues, pulling roughly seven million EU-only instruments out of scope entirely. FX derivatives are being dropped from the regime altogether, with the FCA pointing to equivalent data already captured under EMIR.
The regulator has also sharpened its methodology for assessing whether OTC derivatives count as “traded on a trading venue,” giving firms a clearer basis for reportability decisions, though reportability logic and instrument classification frameworks will still need revisiting.
Conditional Single-Sided Reporting (CSSR) survives as the most contested element of the package. It would let certain firms rely on a counterparty to submit transaction data, cutting duplication. Industry respondents flagged concerns over data-sharing arrangements, contractual protections, reconciliation and inconsistent models across jurisdictions.
The FCA is pressing ahead regardless, noting that most current reports carry no personally identifiable information, which it believes widens the pool of viable use cases. Firms with heavy inter-affiliate or institutional flows should assess whether CSSR offers genuine efficiencies.
Reportable fields are being cut from 65 to 52, removing elements tied to option characteristics, maturity dates, waiver and short-selling indicators, and securities financing transaction flags.
That simplification comes with a catch: data quality expectations are rising, not falling. Firms will need to validate client, trust and natural-person identifiers before execution, keep key fields internally consistent, and tighten governance around reporting quality.
The FCA has also used PS26/15 to clarify long-standing grey areas, including what counts as a reportable transaction, when execution occurs, branch execution responsibilities, fractional instrument reporting, and treatment of index and basket derivatives. These clarifications codify existing practice rather than expanding obligations.
With implementation not due until 2028, the temptation is to wait. The FCA itself has signalled a pragmatic supervisory approach during transition, but that should not be read as a delay in expectations. Firms that use the runway to reassess reportability logic, ARM interfaces, reconciliation processes and governance now will be better placed to capture the cost savings on offer, rather than scrambling through remediation closer to the deadline.
Read the full ACA Group post here.
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