UK MiFIR Transaction Reporting: FCA Reforms and the Road Ahead

How CP25/32 Reshapes Scope, Data Quality, and Implementation Planning

The high stakes of Regulatory Divergence

Transaction reporting remains one of the most complex and risk-sensitive obligations for UK-regulated firms. The Financial Conduct Authority (FCA) has demonstrated a consistently low tolerance for inaccurate or incomplete data. Even minor technical breaches can trigger intense supervisory scrutiny, costly remediation programmes, and lasting reputational damage

UK MiFIR transaction reporting is entering the final phase of regulatory reform. Through Consultation Paper CP25/32, the FCA has proposed changes aimed at simplifying reporting requirements, improving data quality, and refocusing the regime on transactions most relevant to UK market oversight, with final rules expected in the second half of 2026 and a phased implementation thereafter.

While the proposals are designed to reduce long-term reporting burden, they will require firms to reassess transaction reporting scope, data models, systems, and controls, particularly as UK requirements continue to diverge from the EU MiFIR framework.

Strategic Imperatives for 2026

To mitigate these risks, firms must focus on three core areas throughout this year:

• Planning is essential: Firms will need to map existing reporting processes to proposed requirements and identify gaps ahead of rule finalisation.
• Cross-regime consistency matters: Increasing regulatory focus on reducing duplication and improving consistency, where applicable, across reporting regimes under MiFIR, EMIR, and SFTR, requiring a more coordinated data strategy and control framework.
• Technology change is likely: Updates to reporting logic, data fields, and validation rules are expected to require changes to internal systems and ARM integrations.

Regulatory Focus Will Intensify

As the FCA moves from consultation to policy finalisation and implementation, delayed planning increases operational and compliance risk, including:

• Rushed, costly builds
• Increased error rates during transition
• Potential enforcement outcomes and data quality failures

Early preparation enables firms to influence transitional provisions, test reporting logic thoroughly, and align controls ahead of enforcement spikes.

UK MiFIR/MiFID Transaction Reporting Timeline

CP25/32 establishes a multi-year reform programme, with key regulatory milestones extending through 2027, as summarised below.

Why This Timeline Matters

The Preparation Window Is Limited

Following the close of the CP25/32 consultation in February 2026, firms have a relatively short period before final rules are published, after which most of the anticipated 18-month implementation window will run. Delayed planning compresses delivery timelines and increases execution risk.

Change Is Substantive

While the reformed regime is expected to reduce the number of reportable fields, narrow instrument scope, and shorten the historic correction period, these changes will still require material updates to systems, data models, governance frameworks, and reconciliation processes.

Regulatory Divergence Continues

Post Brexit, the EU and UK transaction regimes began to diverge. In 2024, EU MiFIR expanded the scope of reportable items, and in 2025 ESMA was also consulting on radical changes on reporting (be it EMIR or MiFIR). . Firms operating cross-border cannot rely on a single harmonised solution and will need UK-specific reporting logic, controls, and operational processes.

Transitional Provisions Will Be Critical

The FCA is expected to issue transitional guidance and supporting Handbook changes following the main Policy Statement and ahead of go-live. Firms will need to monitor these developments closely to ensure implementation plans remain aligned with final requirements.

Current Pressures in Transaction Reporting Processes

Against this backdrop of ongoing supervisory scrutiny and operational complexity, UK firms continue to face several key pressures in their transaction reporting processes.

1. Data Capture and Quality

Data gaps, reconciliation breaks, and complex instrument structures drive manual intervention and increase reporting error risk.

2. Regulatory Change and Divergence

Divergence from the EU MiFIR framework means firms cannot simply align UK and EU reporting models, often requiring parallel builds and bespoke compliance logic.

3. Reform Uncertainty

Although the reforms are expected to deliver long-term cost savings, they will require system changes, policy updates, vendor coordination, and testing ahead of final rule confirmation and the switching cost may be significant.

4. Enforcement Risk

The FCA has demonstrated a low tolerance for inaccurate or incomplete reporting. Even technical breaches can lead to supervisory scrutiny, remediation programmes, and reputational impact.

Taken together, these pressures make transaction reporting one of the most complex and risk-sensitive regulatory obligations facing UK-regulated firms.

Why Firms Use Specialist Reporting Solutions like Complyport

Specialist regulatory reporting platforms are increasingly used by firms to manage the scale, complexity, and change associated with MiFID/MiFIR transaction reporting. Such solutions typically support:

• Automated data capture, enrichment, and validation to improve consistency and reduce manual effort
• Regulatory logic aligned to evolving UK MiFIR requirements
• Strong control frameworks, auditability, and governance support
• Scalability to accommodate future regulatory change and additional reporting regimes

In an environment of ongoing reform and heightened supervisory scrutiny, these capabilities help firms reduce operational risk and support a more controlled and sustainable compliance model.

Contact our team of experts for more information or any assistance you may require. By leveraging Complyport’s MiFIR reporting solution, you gain access to a powerful platform and a dedicated team committed to ensuring your compliance success.