The UK MiFIR transaction reporting framework is entering its most consequential period of reform since the introduction of MiFIR in 2018. Through Consultation Paper CP25/32, the FCA has set out proposals to simplify and rationalize the regime, reduce the scope of reportable instruments, remove fields deemed to be of limited regulatory value and materially lower compliance costs for firms. The new framework is expected to take effect in the first half of 2028.
Against that backdrop, some firms may be tempted to see transaction reporting as a diminishing priority or to defer investment while awaiting regulatory clarity. That interpretation would be misplaced. The direction set out in CP25/32 does not reduce the importance of accurate and complete reporting; It raises it.
Simplification is a Mechanism for Better Data, Not Lower Standards
A central theme of CP25/32 is that the current regime has become overly complex, costly and difficult to operate reliably. The FCA’s response is not to relax its expectations, but to remove friction so firms can focus on submitting high-quality data. The consultation is explicit that streamlining requirements should result in a higher proportion of complete, accurate and timely transaction reports.
Fewer fields and a narrower reporting perimeter increase supervisory focus on what remains. In a simplified regime, errors are more visible, explanations are harder to justify, and tolerance for systemic weaknesses is likely to be lower. Firms that allow current accuracy standards to slip on the assumption that reform equals leniency risk finding themselves more exposed, not less.
Transaction Reporting is Now Core Regulatory Infrastructure
The FCA no longer treats transaction reporting as a single-use market abuse tool. It has become a foundational supervisory dataset that supports market surveillance, financial crime detection, conduct supervision, and firm risk profiling.
This expanded reliance changes the stakes. Inaccurate or incomplete reporting does not simply breach a technical obligation. It undermines the regulator’s confidence in a firm’s controls, governance and ability to manage conduct risk. As the FCA becomes increasingly data led, the quality of transaction reporting plays a direct role in shaping supervisory engagement and enforcement outcomes.
2025 Enforcement Action Confirms Expectations have not Softened
FCA enforcement activity makes clear that reporting reform has not translated into reduced supervisory pressure. In fact, 2025 marked a notable escalation in action against firms with transaction reporting failures.
In January 2025, the FCA issued its first fine under UK MiFIR specifically for transaction reporting breaches, fining INFINOX Capital Limited £99,200 for failing to submit more than 46,000 transaction reports relating to single-stock contracts for difference. The FCA noted that the omission of these reports risked market abuse going undetected and highlighted weaknesses in the firm’s systems, controls and escalation processes.
Later in the year, the FCA took stronger action against Sigma Broking Limited, imposing a £1,087,300 fine for submitting nearly 925,000 inaccurate transaction reports over a five-year period. Almost all of the firm’s reportable transactions during that time were affected. The FCA described the failings as serious and sustained, linked them to incorrect system configuration and weak governance, and extended enforcement action to senior managers through personal fines and prohibitions.
These cases are particularly instructive in the context of CP25/32. Both relate to long-standing regimes that were already well understood, and neither firm was operating in regulatory uncertainty. The message is clear: Accurate transaction reporting remains a baseline expectation, and upcoming reform does not create immunity from scrutiny.
The Transition Period is Itself a Risk Event
Between now and the introduction of the new MiFIR transaction reporting framework, firms face a prolonged period of transition. Existing MiFIR reporting obligations continue to apply, including correction, back-reporting and recordkeeping requirements. At the same time, firms are redesigning reporting logic, re-scoping instruments, adapting to new field structures and reassessing data sources such as FIRDS.
Looking back at MiFID I and MiFIR transition periods, we observed a decline in reporting quality. Firms that deprioritize current accuracy because the rules are changing risk carrying unresolved issues into the new regime, where supervisory tolerance is likely to be lower and historical weaknesses harder to defend. Parallel processes, incomplete remediation, inconsistent interpretations and under-resourced change programs all increase the risk of reporting errors and control failures.
Proportionality Increases Accountability
By consciously removing requirements that it considers low value, the FCA is also removing many of the traditional explanations firms have relied on for poor reporting quality.
In a more proportionate regime, accountability becomes clearer. Errors are more directly attributable to system configuration, data ownership, governance and control effectiveness. This reinforces the need to invest now in sustainable reporting architectures, clear ownership models and robust assurance.
Accurate Reporting Protects Firms as Well as Markets
While transaction reporting is a regulatory obligation, it is also a critical internal risk management tool. High-quality MiFIR transaction reporting data underpins effective surveillance, conduct risk monitoring, best execution analysis and issue investigation. It provides a defensible audit trail when firms are challenged by regulators and supports credible engagement during reviews or incidents.
Looking ahead, CP25/32 also sets out a broader cross-authority vision of closer alignment among MiFIR, EMIR and SFTR reporting. As data is reused and shared across regimes, weaknesses in transaction reporting will increasingly have downstream consequences beyond a single obligation.
Enter the 2028 Regime from a Position of Strength
The reforms proposed in CP25/32 should be welcomed. They offer firms the opportunity to simplify, reduce cost and improve resilience. But they do not reduce the importance of accuracy and completeness. If anything, they heighten it.
Firms that continue to prioritize transaction reporting quality throughout the transition period will enter the new regime with supervisory credibility, cleaner data foundations and fewer legacy risks. Those that treat reform as a reason to defer investment or relax controls risk learning, through enforcement, that reporting discipline was never optional.
Engaging a MiFID II transaction reporting consultant to conduct an independent audit or health check can be a valuable investment, providing senior management with clear transparency and assurance of the accuracy and robustness of the firm’s reporting.
