The UK’s proposed equity consolidated tape is framed as a response to long-standing fragmentation in equity market data. By aggregating post-trade information and an attributed best bid and offer across trading venues, the tape is intended to provide a single, standardised view of UK equity trading. At the same time, transaction reporting under the Markets in Financial Instruments Regulation (MiFIR) continues to operate as a supervisory control regime, focused on the timely delivery of granular execution data to regulators. These two datasets serve different purposes, are produced on different timelines, and are governed by different rules. The challenge for firms will be explaining how they relate to one another.
The framework for the UK equity consolidated tape is set out in Consultation Paper CP25/31 issued by the Financial Conduct Authority. The consultation opened on 19 November 2025 and, following an extension, closes on 13 February 2026. The paper outlines obligations on trading venues and Approved Publication Arrangements (APAs) to contribute data, alongside governance and operational expectations for a future Consolidated Tape Provider (CTP). While the tape is positioned as market infrastructure rather than a regulatory reporting regime, its outputs will inevitably be compared with supervisory datasets once operational. The indicative timeline points to a tape becoming live around 2027, subject to final rules and provider selection.Transaction reporting under the EU MiFIR has a different origin and objective. Article 26 of the regulation requires investment firms to report transactions in financial instruments to their national competent authority (NCA) as quickly as possible and no later than the close of the following working day (T+1). The intent is supervisory oversight: enabling regulators to monitor market abuse, assess systemic risk and reconstruct trading activity. Reports are submitted on a firm-by-firm basis, using detailed schemas defined by the European Securities and Markets Authority (ESMA). The resulting dataset is regulatory in nature, not a public market view.
The Reconciliation Challenge
These differences become visible when firms subject to both regimes attempt to reconcile the two. The CT designed for near-real-time dissemination. Its value proposition rests on providing an immediate, consolidated picture of trading activity and price formation. EU MiFIR transaction reports, by contrast, reflect what firms knew at the time of reporting, after trade capture, enrichment and validation processes have completed. Even where the underlying trade is the same, the timestamps, enrichment logic and submission cut-offs will not align. From a control perspective, this creates a structural gap between what the market sees on trade date and what regulators receive the following day.Instrument identification is another area where reconciliation friction emerges. MiFIR transaction reporting relies on the International Securities Identification Number (ISIN) as the primary instrument identifier, supplemented by venue codes and segment Market Identifier Codes (MICs) to describe where and how a trade was executed. The CT aims to normalise instrument and venue information to support aggregation across markets. In practice, firms already experience mismatches in ISIN usage across asset classes, corporate actions and trading segments. When a public tape introduces its own canonical view, firms will need to demonstrate how their regulatory reports map to that view, even where identifiers differ in form or granularity.
Venue attribution further complicates this picture. The CT aggregates trades across lit venues and over-the-counter activity that is subject to transparency requirements. MiFIR transaction reporting applies specific rules to determine which venue code should be reported, including the use of segment MICs and, in certain cases, the “off-venue” identifier XOFF. Systematic internaliser (SI) activity introduces additional distinctions. A trade that appears as part of an aggregated tape print may carry a different venue attribution in a MiFIR report, reflecting execution responsibility rather than publication logic. Explaining these differences will be a necessary part of supervisory engagement once both datasets are in use.
Timing expectations reinforce this need for explanation. The CT proposals emphasise transmission of data to the tape provider as close to real time as possible. MiFIR reporting obligations, by contrast, are explicit about the T+1 deadline. Firms therefore face a situation in which regulators and market participants can observe a trade on the tape before the corresponding transaction report has been submitted. From a governance perspective, this places weight on internal reconciliation controls that can account for latency rather than eliminate it.
The regulatory context underscores why this matters. The UK equity CT sits within a broader policy agenda focused on market efficiency, data costs and transparency. Transaction reporting remains anchored in market integrity and supervision. Neither regime is presented as replacing the other. Instead, firms are expected to operate both, with clear controls and evidence trails. As ESMA has emphasised in its work on MiFIR data quality, inconsistencies across datasets are treated as indicators of weak reporting processes unless firms can provide a clear rationale.
Preparing for Convergence
For firms, preparation therefore centres on data governance rather than system replacement. Identifier cross-walks that link ISINs to any CT instrument keys will be required. Venue and execution flag logic will need to be documented in a way that supports both public aggregation and regulatory attribution. Reconciliation processes will need to account for timing differences explicitly, distinguishing between expected latency and genuine breaks. These are not new disciplines, but the visibility of a public CT raises their profile.
As the February 2026 consultation deadline approaches, attention will turn to the final design choices made by the FCA and the operational model adopted by the chosen CTP. For transaction reporting teams, the CT doesn’t introduce a new obligation, but it does introduce a new comparator. The relationship between these two views of the market will become part of routine supervisory dialogue, shaped by the rules set out in MiFIR and the UK’s evolving market data framework.
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