Will the FCA’s transaction reporting reforms make compliance simpler?

What happened?

The reforms set out in the FCA’s Policy Statement PS26/15: Improving the UK transaction reporting regime are intended to make the regime more proportionate and focus reporting on the data the FCA considers most useful for supervision and market abuse monitoring. 

The changes, published on the 3rd August 2026, look at how the current framework was introduced under Markets in Financial Instruments Directive II (MiFID II) and has been applied in the UK since 2018. While it increased transparency across financial markets, it also created a highly detailed reporting regime that has required significant investment in systems, controls and oversight. Over time, firms, industry bodies and reporting providers have questioned whether every reporting requirement still delivers meaningful regulatory value. 

Following consultation with the industry, the FCA concluded that parts of the regime could be simplified without undermining its ability to supervise markets effectively. The resulting reforms aim to remove duplication, reduce unnecessary reporting and improve the usefulness of the information firms submit. 

The changes also reflect a broader trend in UK financial regulation. Since Brexit, the FCA and HM Treasury have been reviewing inherited EU legislation to identify opportunities to tailor requirements more closely to UK markets. Transaction reporting is one of the most significant examples of that process. The important point is that the FCA is not moving away from transaction reporting. Instead, it is refining what information it believes is genuinely needed to support effective supervision. 

What has the FCA actually changed in the UK transaction reporting regime?

Several aspects of the transaction reporting regime will change under the new framework: 

• The number of reportable fields will reduce from 65 to 52. Certain financial instruments will leave scope, including around seven million instruments that are only tradeable on EU venues. The reforms also remove foreign exchange (FX) derivatives from transaction reporting requirements. 

• The FCA is also reducing the default back-reporting period from five years to three years, which it estimates will reduce the volume of historical report resubmissions by around a third 

Taken together, these changes are expected to reduce reporting volumes and simplify reporting processes across the industry. For firms that have invested significant time and resources managing transaction reporting obligations, the reforms should remove some complexity. However, implementation will still require careful planning, particularly where reporting obligations are embedded in systems, controls and operational processes. 

Who is affected?

Which firms are most affected by the UK transaction reporting regime reforms?

The reforms affect investment firms, trading venues, approved reporting mechanisms (ARMs) and other organisations involved in transaction reporting. 

For many firms, the first step will be to understand whether all business lines, products and legal entities remain within scope. This is particularly relevant for larger groups where reporting obligations may vary between entities. A change in instrument scope does not automatically mean every part of the business will experience the same reduction in reporting requirements. Firms that operate across multiple jurisdictions may also need to assess how UK reporting obligations interact with separate EU requirements.

Where could implementation of the reforms become challenging?

• Reviewing reporting logic 

Many firms have spent years building systems and controls around existing UK Markets in Financial Instruments Regulation (UK MiFIR) requirements. Changes to reportable fields and instrument scope mean those frameworks will need careful review. Reporting rules are often embedded in upstream systems, reconciliations, exception management processes and outsourced arrangements – thus removing requirements can be as complex as introducing them. 

• Understanding the FX derivatives position 

Removing certain FX derivatives from transaction reporting is likely to attract particular attention. The FCA believes much of this information is already available through the UK European Market Infrastructure Regulation (UK EMIR) reporting regime, reducing duplication between regulatory regimes. 

• Appreciate full context 

It is important firms don’t assume they can immediately stop reporting these transactions. The FCA’s supervisory flexibility is conditional and depends on the same transactions being reported under the UK EMIR. A detailed assessment of existing obligations will be required before operational changes are made. 

• Preparing for further technical requirements 

Although the new regime is due to take effect in April 2028, further implementation details are still to come. The FCA plans to consult on areas including reporting schemas, validation rules and guidance. As a result, firms may need to balance early planning with the recognition that some implementation decisions will depend on future regulatory details. 

Does simpler reporting mean lower regulatory expectations?

The FCA has outlined that these reforms are intended to improve efficiency, not reduce accountability. Transaction reports remain a key source of information for market abuse surveillance and supervisory activity. Firms will remain responsible for the accuracy, completeness and timeliness of their submissions. While fewer reports may be required, the data that remains within scope will continue to receive significant regulatory attention. 

Strong governance remains central to effective transaction reporting. Clear ownership, effective oversight, management information and robust exception management processes will all remain important. In many cases, the reforms also present an opportunity for firms to review existing reporting arrangements and strengthen governance around the data they continue to submit.

Actions to take

What should firms be doing now?

• Assess the impact on your business: Firms should begin by identifying which current reporting obligations may change under the new regime. Understanding the impact across entities, products and business lines will help firms prioritise future implementation activity and avoid unnecessary work. 

• Review existing dependencies: Reporting processes often contain manual workarounds, legacy controls and operational dependencies that have developed over time. Documenting those arrangements now can make future implementation significantly easier. 

• Focus on long-term effectiveness: The greatest benefit may not come from a reduction in reporting fields or reporting volume. Instead, firms should view the reforms as an opportunity to simplify reporting frameworks, improve accountability and strengthen control over regulatory data. 

What does this tell us about the FCA's wider direction?

The reforms reflect a broader shift in regulatory thinking. Across several areas of regulation, the FCA has focused on improving the quality and usefulness of regulatory data rather than simply increasing reporting requirements. The objective is to ensure firms provide information that supports effective supervision without creating unnecessary operational burden. For firms, this demonstrates a continued emphasis on data quality, governance and accountability.