The UK MiFIR transaction reporting regime is changing.
Tom Soden, Head of Regulatory Strategy & Insights at Novatus, shares his thoughts on the FCA’s latest consultation paper to help firms prepare for implementation.
It has been a short while since PS26/15 interrupted the summer holidays and started the clock on a 20-month implementation period for the new UK transaction reporting regime. The FCA promised a draft schema and new reporting guidelines in October 2026. CP26/34 delivers on that commitment – and with time to spare.
New guidelines are here, more will follow
With UK MiFIR fast approaching its 6th birthday, EU guidelines remain as relevant as ever. There are a few reasons for this. UK MiFIR is, of course, pretty similar to EU MiFIR. It would make little sense to create significant divergence in how to report the same transactions under each regime.
There is also the difficult question of how existing ESMA guidelines, to which the FCA contributed, should be adapted for the UK regime. That question will be answered in the new Transaction Reporting User Pack (TRUP).
Those with corporate memory of transaction reporting before 2018 will be comforted to find a new look and feel to TRUP. But we will have to wait a little longer to see the final version.
The FCA is first asking for feedback on its approach to converting EU guidelines and Q&As. There is a trade-off between improving things and creating divergence. Whatever choices are made, changes will need to be reviewed carefully.
CP26/34 does contain some new guidelines which will be added to TRUP. These focus on a logical starting point: areas of the new regime not adequately covered by existing guidelines.
Of particular interest will be materials for the mildly contentious Conditional Single-Sided Reporting (CSSR), which is replacing the RTS 22 Article 4 transmission mechanism. Example 4 shows how CSSR can be used for DEAL trades, an entirely new feature that will appeal to principal trading firms. In this scenario, the sending firm identified in MAR 14 field 25/26 should be the same as the buyer/seller.
With careful planning, some firms may be able to utilise CSSR to materially reduce the number of transaction reports submitted for some order flows, including intra-group trading activities. Time will tell whether this cost-saving proves sufficiently attractive for firms to experiment with new operational processes.
New Example 6 highlights an existing peculiarity with the transmission mechanism: where multiple sending firms are involved in a transaction chain, only the original sending firm is identified in the report submitted by the ultimate receiving firm. We see limited evidence of Article 4 transmission being utilised in this way and believe this is unlikely to change.
The FCA confirms that allocation details must be provided when a sending firm aggregates orders for or from multiple clients (Example 7). This is logical, despite being omitted from the information requirements in MAR 14.10. The often post-trade nature of allocations may restrict the feasibility of CSSR in these scenarios.
There are a variety of new examples for package trades. These should be welcomed by firms which have struggled to manage the concept of a complex trade (not aided by superficial existing guidelines).
The new package trade definition will help harmonise reporting processes for firms with integrated data architecture for MiFIR and EMIR reporting. For others, this area may be tricky to navigate, with more trading scenarios and products captured. This section of TRUP may need to be developed further still.
Most scenarios for the new client indicator field are predictable, with the logic applied matching similar logic for the country of branch for the buyer/seller. However, there is a change in the treatment of these fields where CSSR takes place: they must now be reported from the perspective of the receiving firm, not the sending firm.
This likely follows the decision to exclude these fields from the information that must be exchanged between the sending and receiving firm. It could though be reasonably concluded that the buyer/seller will be a client of the sending firm where the sending firm acts in AOTC/MTCH capacity.
UK branch firms should familiarise themselves with the guidelines around branch execution. While these probably represent confirmation of existing expectations (rather than a new approach), it is possible these may not align with existing practices, particularly around ‘cross-branch execution’ and the expectation to ‘look through’ intra-group branches. Now is the time to review and provide feedback to the FCA.
Overall, the guidelines provide some welcome additional clarity. The FCA has clearly responded to feedback in considering where to develop examples. But until we see the full user pack, some firms are going to be left with questions. Assumptions may need to be made for business planning with the implementation clock running.
Weekend plans and transitional provisions
CP26/34 also contains a new chapter of ‘transitional provisions’ (TP 5). These clarify regulatory expectations for transactions with a T+1 reporting deadline falling on 3 April 2028. Common sense has been applied, and firms will have a choice: report early with the existing schema, or report on 3 April 2028 with the new schema.
This may not seem important in the grand scheme of things, but firms should plan early to avoid unpleasant surprises over the implementation weekend.
The FCA also confirms there will be no amnesty for data quality issues once the new regime takes effect. Following TP 5.3.2G, back reports will need to be submitted under the new schema from 3 April 2028. This includes transactions executed under the current regime (and within the 3-year back reporting period).
Inconsequential amendments
The FCA’s Handbook contains miscellaneous references to the current transaction reporting regime. These will be removed or replaced by equivalent references in the new regime.
These changes should generate little interest, perhaps other than to note the welcome banishment of the Short Selling Indicator field from related record keeping obligations.
What happens next?
The consultation closes on 6 November 2026 – a shorter window for feedback, reflecting the modest nature of proposals. Final rules will be made once industry responses have been considered.
Preliminary testing and logic design can meanwhile begin using draft versions of the new validation rules and reporting schema. Changes could still be made to these artefacts, subject to feedback received.
Onwards, then, to the full user pack. This will be consulted on in Q1 2027 and finalised before 3 April 2027, giving firms time to adjust their final preparations.
Novatus helps firms solve transaction reporting challenges through expert consulting and the En>ACT platform, delivering real-time visibility and ensuring accurate, complete, and timely reporting. To speak to Tom and our team of experts about these changes, please get in touch at info@novatus.global.
