The FCA has issued a landmark consultation setting out one of the most significant changes to the UK’s MiFIR transaction reporting regime since its introduction.
CP25/32 proposes a comprehensive redesign aimed at simplifying obligations, reducing unnecessary operational burden, and supporting a more proportionate and cost-efficient framework for reporting institutions, claims ACA Group.
The move signals a decisive shift towards a streamlined, UK-focused regime that prioritises clarity, market integrity, and economic competitiveness.
For years, transaction reporting has been a persistent source of expense and complexity for UK firms. The latest consultation marks a turning point, reflecting the regulator’s intent to ease reporting pressures without compromising oversight. By focusing on proportionality and efficiency, the FCA aims to reduce friction, strengthen financial crime defences, and create a more supportive environment for UK market growth.
On 21 November 2025, the FCA published CP25/32 outlining changes that would reshape how firms report under UK MiFIR. The proposals include refinements designed to cut complexity and align more closely with the UK’s broader competition and regulatory objectives. A central component of the reform is the removal of 13 reporting fields deemed no longer necessary, alongside updates to harmonise terminology with UK EMIR. This includes retiring the concept of a “complex trade” and replacing it with “package transaction”, which will require new linking fields for instruments reported individually.
The changes to scope and instrument reportability stand to deliver substantial cost savings. Reporting will be limited to instruments tradeable on UK venues only, a shift expected to save firms £31.5m annually while removing obligations for 6m instruments traded on EU venues. FX derivatives will also be dropped from MiFIR reporting, as the FCA concludes existing EMIR data is sufficient. The paper offers further clarity around structured products, indices, and baskets, while confirming retention of the exemption for CPMI firms due to disproportionate cost-benefit implications.
Transmission and reporting processes will also be simplified. Amendments to the Article 4 Transmission regime will enable receiving firms to report for both parties under defined conditions. The FCA also proposes reducing the back-reporting window from five years to three, easing long-standing operational pressures while maintaining appropriate regulatory oversight.
System and data enhancements form a crucial part of the modernisation effort. FCA FIRDS will be formalised as the authoritative source for determining reportability, with exceptions only for trades executed on UK venues. The regulator also plans improvements to the Market Data Processor and confirms that XML will remain the standard reporting format. The concept of “admission to trading” will extend to all venue types, including MTFs, helping eliminate ambiguity around eligibility.
Looking ahead, the FCA signals a longer-term ambition to harmonise reporting across MiFIR, EMIR and SFTR. Although a single “report once” model is not imminent, the regulator outlines three guiding principles: data collection should be purpose-driven, firms should only report information once, and sharing across authorities should be optimised. The removal of FX derivatives from MiFIR illustrates this direction of travel.
To support implementation, the FCA will introduce a new transaction reporting user pack in 2026, consult on aggregate client account guidance, and establish a cross-authority working group to design a more aligned reporting framework. Final rules are expected in the second half of 2026, followed by an 18-month transition window.
The FCA encourages firms to begin preparations now, including assessing affected reporting fields, planning system updates, and mapping internal transition roadmaps. Early action will minimise remediation risk and prevent costly operational disruption.
For firms seeking independent assurance, solutions such as ACA’s Regulatory Reporting Monitoring and Assurance (ARRMA) offering can help assess accuracy, completeness, and timeliness. According to ACA, 93% of reporting submissions it reviewed in 2025 contained at least one error, highlighting the ongoing need for rigorous oversight. ARRMA provides automated reconciliations, audit-ready output, and specialist guidance to strengthen both EMIR and MiFIR reporting frameworks.
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