When the UK’s Financial Conduct Authority (FCA) talks about innovation in financial markets, it is often interpreted as guidance for firms and RegTech providers. But one of the lesser-recognised realities – made clear in its recent speech on innovation and human expertise – is that the FCA is itself one of the country’s largest consumers of market and transaction data. It processes over 8 billion transaction reports a year and hundreds of millions of records a day, supervises increasingly complex reporting regimes, and runs a large-scale technology and analytics stack to ingest, clean and analyse this data.
This is why the regulator’s latest signals around MiFID, EMIR and SFTR reform deserve close attention. The FCA is preparing a Consultation Paper that could shape the UK’s next generation of transaction reporting – less fragmented, more consistent across regimes, and more aligned to the way markets actually function. For RegTech providers, compliance teams and market operators, the direction of travel is not simply about meeting rules: it is about understanding how the UK’s supervisory architecture itself is evolving.A recent speech by FCA director of market oversight Dominic Holland, underscores an extraordinary volume and diversity of datasets passing through the FCA’s Market Oversight function – far more than most market participants appreciate.
- MiFID II transaction reporting: more than 8 billion reports per year
- Order book data: around 400 million messages per day
- EMIR reporting: approximately 53 million derivative reports per day
- SFTR reporting: over 1 billion reports per year
This scale matters because it places the regulator not merely in the role of a data recipient but in that of an industrial-scale analytics engine, capable of identifying outliers, modelling behavioural patterns and pinpointing reporting deficiencies with increasing precision. It also explains the FCA’s emphasis on data quality, cross-regime alignment and streamlined reporting obligations: when volumes reach billions of records, even small inefficiencies quickly compound, and fragmented schemas, inconsistent field definitions and duplicated reporting flows create unnecessary operational burdens for firms while adding friction to supervisory analysis.
The FCA describes its long-term aim as seeking to “streamline these requirements to ensure they work in harmony.” This vision aligns closely with the joint Transforming Data Collection (TDC) programme led by the Bank of England (including the Prudential Regulation Authority) and the FCA, which focuses on reducing reporting burden, improving data quality and modernising the way regulators collect and use data. It also reflects what compliance teams have known for years: although MiFID II, EMIR and SFTR are grounded in EU legislation, they evolved separately, each with its own fields, processes, validation logic and operational timelines. Firms therefore face three distinct workflows for what is, in practical terms, reporting on the same lifecycle of financial instruments.
Based on the FCA’s existing priorities and previous work on data collection, the Consultation Paper could explore themes such as:
Data Model Alignment: Creating greater consistency across regimes to reduce duplication and simplify reconciliations. This could include harmonised field definitions, shared identifiers and a more unified approach to lifecycle event reporting.
Improving Rules & Guidance: Clarifying ambiguous areas in the UK’s post-Brexit reporting framework, addressing pain points such as instrument reference data, transaction categorisation and the treatment of complex products.
Streamlining End-to-End Processes: Reducing operational burdens by identifying overlaps and unnecessary divergences between MiFID, EMIR and SFTR.
Strengthening Supervisory Utility: Ensuring that the data the regulator receives is actually useful in spotting market abuse, systemic risk or disorderly trading.
A notable shift in tone is the FCA’s portrayal of transaction reporting not as a static compliance process but as part of a broader digital market ecosystem. Reporting feeds into surveillance, which feeds into risk monitoring, which in turn feeds back into rulemaking. This continuous cycle means the quality, structure and consistency of data matter more than ever.
When Holland explains that he is “not only in this role to police reporting requirements or pursue an individual for insider trading” but is “also here to help” and to “come up with solutions that can benefit the wider economy and market”, he is signalling a supervisory philosophy that values both enforcement and collaboration.
This is a subtle but important repositioning:
- Firms are not just consumers of rules – they are co-contributors to a shared data environment.
- RegTech providers are not just automation vendors – they are infrastructure partners shaping the quality and utility of the UK’s financial data supply chain.
- Regulators are shifting from template-based oversight to data-driven, analytics-led supervision.
For the UK reporting ecosystem, this is not evolution; it is transformation.
The Data Quality Challenge
The most consistent theme across the FCA’s remarks is data quality: accuracy, timeliness, completeness, consistency and explainability. With reporting volumes in the billions, high-quality data is the only way for the regulator to run reliable analytics and identify emerging risks.
Poor-quality submissions not only hinder supervision but also create firm-level risks: duplicate reporting, broken lifecycle chains, incomplete UTIs, mismatched counterparties and unnecessary remediation projects.
For firms, this is a clear directive: automated reporting without strong oversight is no longer viable. RegTech solutions must embed controls that are not only fast and scalable but also transparent and explainable.
A Reporting Future Built on Coherence and Consistency
For firms and their RegTech partners, the upcoming consultation offers a chance to influence the next decade of UK market reporting – one where data quality, alignment and analytical utility define success.
The FCA’s message is clear – the UK reporting ecosystem is becoming more coherent, more data-driven and more aligned across regimes. And for those willing to invest in better data, better technology and better governance, the new landscape could be far more efficient than the one it replaces.
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