The Financial Conduct Authority’s latest transaction reporting consultation sets out how firms would apply rules that change reporting responsibilities, client data exchanges and the treatment of historical records. Preparing for the April 2028 deadline will require decisions about who supplies reporting data and how systems preserve it through the transition.
Published in August 2026, Policy Statement PS26/15 – Improving the UK transaction reporting regime set out final rules for a new UK transaction reporting regime, reducing reporting requirements and introducing optional conditional single-sided reporting.
Consultation paper CP26/34 – Preparing for the new transaction reporting regime published in October, follows with proposed guidance, worked examples and transitional provisions. Draft schemas and validation rules gives firms more detail for assessing changes to reporting systems.
Governance Decisions
The proposed guidance asks firms to consider the supervisory, governance and operational arrangements surrounding trading activity when determining whether a transaction was executed through a UK branch. Relevant considerations include who supervises investment and execution decisions, which branch receives an order and whose trading-venue membership supports execution.Physical location alone does not determine the answer. The consultation describes a New York trader working temporarily in London while remaining under New York supervision and mandate. Firms should document which entity and branch retain responsibility and the basis for their reporting decision.
Reporting logic must therefore reflect the arrangements under which desks operate. A change in supervision or branch mandate could require compliance and operations teams to review the assumptions feeding their reports.
Broker Workflows
A transaction between investment firms can trigger reporting obligations for more than one firm. The new optional conditional single-sided reporting framework allows one firm to submit the report, provided the other supplies the required information and meets the framework’s conditions.
The proposed framework requires a written agreement specifying at least the deadline for supplying required information. FCA guidance says the agreement should precede trading. CP26/34 explains how trading capacity determines whose identity appears in the report. Where the sending firm acts as principal, the receiving firm identifies that firm as buyer or seller. In other capacities, it identifies the relevant clients.
For orders involving multiple client allocations, the sending firm must supply quantities for each client. The receiving firm must identify the original sending firm, even when another intermediary passes the information along. For block orders allocated across client funds, the proposed guidance addresses how those allocations enter transaction reports. Managers using conditional single-sided reporting must supply the relevant client details and quantities within the agreed information deadline. The guidance does not prescribe a new method for allocating execution prices across funds.Under this arrangement, the receiving firm combines information supplied by the sending firm, such as client identities and allocations, with details of the execution from its own records. Responsibility follows the source of the error: the sending firm remains accountable for the accuracy and completeness of its information, unless the receiving firm’s actions cause the reporting error.
These distinctions matter when firms investigate an incorrect report: they need to establish whether the failure arose in supplied client data or subsequent processing. If the sending firm does not meet the conditions for single-sided reporting, such as supplying the required client information within the agreed deadline, FCA guidance says it should report the transaction itself.
Data Dependencies
Firms seeking early relief face a dependency on reference data. The FCA has said it will not take action against firms that stop reporting instruments tradeable only on EU venues during implementation. However, firms using its Financial Instrument Reference Data System (FIRDS) to identify reportable instruments may continue generating reports while those instruments remain in the dataset.
Subject to legislative changes, the FCA is considering removing them before April 2028. Firms and reporting providers would then need to align their scope decisions with the changed reference-data population.
Package transactions introduce another data requirement. They replace the previous complex-trade concept and need not share one price or execute at the same time. Firms must link reportable legs through a common package identifier, including where only one leg requires reporting.
Systems therefore need to retain the relationship between transactions negotiated under one economic agreement. Individual trade records and execution timestamps may not provide enough information to reconstruct that relationship later.
Migration Controls
From 3 April 2028, FCA systems will stop accepting the existing formats under the UK MiFIR.
Under the proposed transitional provisions, firms could retain historical records in their original format. Corrections submitted after implementation would follow the new requirements, including for transactions reported before the change.
The FCA would not require information that firms had no obligation to supply when the transaction occurred. Firms would nevertheless need to retrieve old records and translate them into an acceptable submission. Testing that process would establish whether mappings and retained source data remain usable after legacy reporting systems close.
CP26/34 closes on 6 November. The FCA plans a further consultation on its Transaction Reporting User Pack in early 2027 and publication of the final version by 3 April 2027. Firms can flag scenarios the proposed examples leave unresolved, including allocation failures, package identification and corrections that depend on historical records.
Subscribe to our newsletter
