FCA Overhauls UK Transaction Reporting Regime: Key Implications and Next Steps for Firms | Kroll

Regulatory Updates

August 12, 2026

FCA Overhauls UK Transaction Reporting Regime: Key Implications and Next Steps for Firms

The UK Financial Conduct Authority (FCA) has published Policy Statement (PS26/15), improving the UK transaction reporting regime, finalizing substantial reforms to the UK's MiFIR transaction reporting framework. The reforms are designed to streamline reporting requirements, improve data quality and reduce unnecessary regulatory burden, while preserving the effectiveness of market surveillance and regulatory oversight.

The FCA estimates that the changes will deliver annual industrywide savings of more than £100 million. The new regime will come into effect on April 3, 2028, although firms should begin assessing the impact of the reforms well in advance of implementation. However, the FCA has indicated that firms may benefit from supervisory flexibility in certain areas from August 3, 2026.

Why Has the FCA Made These Changes?

Transaction reports remain a critical supervisory tool for detecting market abuse, monitoring trading activity and supporting the FCA's broader supervisory objectives. However, the feedback from market participants has highlighted that certain aspects of the current framework impose significant operational and compliance costs while delivering limited incremental regulatory benefit. The FCA has estimated that firms have spent approximately £493 million complying with UK MiFIR transaction reporting requirements. Through PS26/15, the FCA aims to reduce this burden by removing duplicative and low-value reporting requirements while preserving the data necessary to support market abuse detection, effective supervision and maintenance of market integrity.

Key Changes Introduced by the FCA

Reduction in Reportable Fields

The FCA has reduced the MiFIR reportable fields from 65 to 52. This change is intended to remove data elements considered less useful from a supervisory perspective while allowing firms to focus on reporting higher quality and more relevant information.

Scope Restricted to UK Venue-Traded Instruments

One of the most significant reforms is the proposal to reduce the scope of the transaction reporting regime to financial instruments tradeable on UK trading venues only. Under the current framework, firms are also required to report instruments traded solely on EU venues. The FCA estimates that this change will remove approximately seven million financial instruments from scope, significantly reducing reporting populations and associated reference data maintenance requirements.

Removal of FX Derivatives from the Scope

The FCA has confirmed that FX derivatives will be removed from the scope of UK transaction reporting regime. The FCA considers UK EMIR reporting sufficient for obtaining the required information and expects this change to reduce costs for more than 400 UK firms.

Reduce Remediation Burden

The default back-reporting period will be reduced from five years to three years. This change will reduce the volume of historical corrections and resubmissions that firms may be required to undertake when addressing transaction reporting issues.

Conditional Single-Sided Reporting

The FCA has introduced a conditional single-sided reporting framework whereby a receiving firm may submit a transaction report using information provided by the sending firm. This removes the need for both parties to report a transaction while maintaining effective market oversight.

Supervisory Approach During the Transition

Recognizing the scale of the reforms, the FCA has indicated that it will adopt a flexible supervisory approach in certain areas during the transition period. Further consultation on reporting schemas, validation rules and technical specifications is expected in October 2026. Firms should use this period to assess impacts, define implementation plans and prepare for the transition to the new reporting framework.

Timelines

Milestone
Date
Publication of PS26/15
August 3, 2026
FCA consultation on reporting schema, validation rules and guidance
October 2026 (Date not yet confirmed)
New UK transaction reporting regime takes effect
April 3, 2028
Supervisory flexibility period in certain cases
August 3, 2026 – April 3, 2028

What Should the Firms Do Now?

  • Assess whether the instruments currently being reported will remain in scope under the revised framework
  • Review the impact of the FX derivatives exemption on reporting processes and controls
  • Identify changes required to transaction reporting systems, data sourcing, control and governance frameworks
  • Monitor for upcoming FCA communications on reporting schemas, validation rules and technical guidance, which are expected to be published in October 2026
  • Identify opportunities to reduce reporting costs and operational complexity

Conclusion

The publication represents a significant change to the UK transaction reporting regime. The reforms reduce the number of reportable fields, narrow the scope of reportable instruments, remove certain duplicative reporting obligations and introduce a more proportionate remediation framework. While implementation is not required until April 2028, firms should begin assessing the impact of these changes and planning the necessary enhancements to their reporting frameworks, systems and controls. Early preparation will help firms manage implementation effectively and take advantage of the simplification opportunities created by the new regime.

If you require any assistance with any of the items mentioned above or would like to learn more about how Kroll can support you, please reach out to your usual Kroll representative or any of the contacts listed below.

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