FCA

Financial Conduct Authority (UK)

High Impact

FCA consults on major simplification of the UK MiFIR transaction reporting regime

Published

Nov 11, 2024

Topics

Transaction reporting, UK MiFIR, Market Conduct Sourcebook, RTS 22, RTS 23, RTS 24, Instrument reference data, Market data reporting, EMIR and SFTR alignment

Executive Summary

The FCA has opened consultation CP25/32 on a substantial redesign of the UK transaction reporting regime. The proposals would replace onshored RTS 22, RTS 23 and RTS 24 with new rules in the FCA Market Conduct Sourcebook, following HM Treasury’s stated intention to repeal the existing firm-facing UK MiFIR transaction reporting provisions. The consultation is not a final rule: firms have until 20 February 2026 to respond, and the FCA plans to publish a Policy Statement in the second half of 2026. The package is deregulatory in several areas, including fewer reportable fields, narrower instrument scope, removal of FX derivatives from UK MiFIR transaction reporting, a shorter default back-reporting period and simplified instrument reference data requirements. However, firms would still need to implement material system, data, control and governance changes once final rules are made. The FCA expects an implementation period of around 18 months, to be confirmed in the Policy Statement. Affected firms should assess impacts now and use the consultation window to evidence implementation costs, data-quality risks and dependencies.

What Changed

modifiedNew MAR-based transaction reporting rulebook

Transaction reporting requirements sit in onshored Commission Delegated Regulation (EU) 2017/590, Commission Delegated Regulation (EU) 2017/585 and Commission Delegated Regulation (EU) 2017/580.

New

The FCA proposes to consolidate replacement requirements in its Market Conduct Sourcebook, subject to consultation feedback and final rules.

removedReduced transaction reporting data set

Firms report against the current 65-field RTS 22 transaction reporting template, including the transmission of order indicator.

New

The proposed template would contain 52 fields and remove selected fields assessed as disproportionate.

modifiedNarrower scope of reportable instruments

UK investment firms report transactions in instruments admitted to trading or traded on UK or EU trading venues, or where a request for admission has been made.

New

The proposed scope would focus on instruments tradeable on UK trading venues, with consequential changes such as TVTIC reporting only for UK venue transactions.

removedFX derivatives proposed to leave UK MiFIR transaction reporting scope

FX derivatives are reportable under UK MiFIR where they are admitted to trading or traded on a UK or EU trading venue.

New

FX derivatives would be removed from UK transaction reporting if the proposal is finalised; the FCA may use UK EMIR data and targeted ad hoc data requests instead.

modifiedBack reporting and single-sided reporting

The default back-reporting period is 5 years, and the Article 4 RTS 22 transmission mechanism is limited and little used.

New

Default back reporting would be 3 years, with potential 5-year ad hoc requirements; conditional single-sided reporting would be renamed and broadened under proposed MAR 14.10.

Business Impact

Who is affected

Directly affected

MiFID investment firms and credit institutions with transaction reporting obligations, UK branches of third-country investment firms, UK trading venue operators, systematic internalisers, ARMs, APAs, UK EMIR and UK SFTR counterparties, UK EMIR trade repositories, AIFMD and UCITS firms, market data service providers, and employees responsible for investment or execution decisions.

Indirectly affected

trade associations, professional advisers, reporting vendors, data providers, control teams, compliance assurance teams and clients whose identifiers are used in transaction reports.

Jurisdictions

United Kingdom, UK branches of third-country firms, Cross-border UK/EU reporting operating models

Business processes

Transaction reporting eligibility determination, RTS 22 transaction report generation and submission, Instrument reference data submission and validation, Back reporting and error remediation, Market Data Processor and ARM connectivity, Client identifier onboarding and validation, Trading venue transaction identification code controls, Conditional single-sided reporting arrangements, Reporting governance, reconciliations and breach assessment

Estimated effort

High

Compliance risk

Medium

Affected Reports

UK MiFIR transaction report submission control frameworkInstrument reference data submission and validation processBack-reporting remediation workflowConditional single-sided reporting operating model and counterparty data-sharing proceduresTrading venue and ARM/MDP reporting quality assurance controls

Field	Validation rule
RTS 22 transaction report field population overall	The FCA proposes reducing the number of transaction reporting fields from 65 to 52.
RTS 23 instrument reference data fields	The FCA proposes reducing instrument reference data fields from 48 to 37.
RTS 22 Field 25 - Transmission of order indicator	The FCA proposes removing the field because of persistent data-quality issues and limited regulatory use.
RTS 22 Field 5 - Investment Firm covered by Directive 2014/65/EU	The FCA proposes renaming the field to 'Executing entity is a transaction reporting firm' and updating the content table.
RTS 22 Field 7 and Field 16 - Buyer/seller identification code	For trading scenarios where the counterparty is not known at execution, the FCA proposes requiring the segment MIC of the trading venue, including OTF and non-UK organised trading platform scenarios.
TVTIC field and CON-030 validation	The FCA proposes that TVTIC should be populated only for transactions executed on UK trading venues and that CON-030 should reject reports containing a TVTIC where the MIC relates to a non-UK trading venue.
RTS 22 Field 47 - Underlying instrument code	The FCA plans to relax validation so basket-derivative reports are rejected only where none of the ISINs reported in the underlying instrument field are in FCA FIRDS.
RTS 22 Field 48 - Underlying index name	The FCA plans to align the index list with UK EMIR Table 2, Item 15 and provide guidance on standardised population.
Trust client identifiers	The FCA proposes allowing firms to identify either the trust using an LEI or the trust beneficiary using the applicable national identifier.
Natural person identifiers	The FCA proposes requiring firms to obtain national identifiers before providing a service that triggers a transaction report for the natural person client.
Trading capacity	The FCA proposes guidance requiring the trading capacity to be consistent with buyer and seller field population for DEAL, AOTC and MTCH.

Recommended Actions

7 suggested next steps· derived from source analysis

1
Confirmed actionStep 1 of 7
responses are due by 20 February 2026. If your firm is in scope, decide whether to submit feedback and gather evidence on implementation cost, data-quality risk and the proposed 18-month implementation period.
2
AI generatedStep 2 of 7
run a gap assessment from current RTS 22, RTS 23 and RTS 24 reporting logic to the proposed MAR 14 framework, prioritising field removals, scope filters, validation changes and instrument reference data changes.
3
AI generatedStep 3 of 7
quantify expected volume and cost impacts from EU-only instrument removal, FX derivative removal, shorter back reporting and reduced venue/SI reference data obligations.
4
AI generatedStep 4 of 7
review UK/EU reporting architecture for divergence risk, especially firms using a single reporting engine or shared data model for UK and EU MiFIR reporting.
5
AI generatedStep 5 of 7
evaluate whether expanded conditional single-sided reporting could reduce reporting burden, and identify legal, data-sharing and responsibility-for-accuracy changes needed with counterparties.
6
AI generatedStep 6 of 7
do not start irreversible build solely on the consultation text; maintain design options until the Policy Statement, transitional provisions and transaction reporting user pack are published.
7
AI generatedStep 7 of 7
strengthen existing data-quality monitoring, reconciliation and back-reporting governance now, because the FCA proposes to continue monitoring acceptance rates, error alerts and corrective reporting ratios.

Timeline

publication

Nov 2025

FCA published Consultation Paper CP25/32, 'Improving the UK transaction reporting regime'.

consultation deadline

Feb 20, 2026

Deadline for comments on CP25/32.

other

Date not specified

FCA plans to provide further information about the terms of reference and application process for a cross-authority and industry working group.

publication

Date not specified

FCA plans to publish a Policy Statement finalising the new transaction reporting rules.

implementation

Date not specified

FCA will confirm the implementation period in the Policy Statement; based on feedback received to date, it expects this to be around 18 months.

other

2026

FCA intends to consult on a new transaction reporting user pack.

Sources

AI-generated analysis is based on the following primary sources. Always verify against the official publication.

Consultation PaperFinancial Conduct AuthorityNov 2025
Consultation Paper CP25/32: Improving the UK transaction reporting regime ↗
https://www.fca.org.uk/publication/consultation/cp25-32.pdf
Consultation webpageFinancial Conduct AuthorityMar 2, 2026
CP25/32: Improving the UK transaction reporting regime ↗
https://www.fca.org.uk/publications/consultation-papers/cp25-32-improving-uk-transaction-reporting-regime
Discussion PaperFinancial Conduct AuthorityNov 2024
DP24/2: Improving the UK transaction reporting regime ↗
https://www.fca.org.uk/publications/discussion-papers/dp24-2-improving-uk-transaction-reporting-regime

Related Evidence

Verified source support for this analysis

The evidence agent checks whether the drafted finding is supported by official publications and relevant public source material.

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