The Financial Conduct Authority (FCA) has moved a step closer to replacing the UK MiFIR transaction reporting framework with the publication of consultation paper CP26/34, Preparing for the New Transaction Reporting Regime. Firms that treat the April 2028 go-live date as a distant concern risk being caught short.
According to ACA Group, the core policy changes were settled in PS26/15. This latest consultation turns to the practical side: how firms should prepare for implementation and manage the move away from the existing regime ahead of 3 April 2028. Responses are due by 6 November 2026.
The paper sets out proposed guidance on key parts of the new framework, transitional provisions for the switchover, consequential amendments to Handbook rules and technical standards, and plans for a new Transaction Reporting User Pack (TRUP).
The TRUP will bring reporting guidance, instrument reference data guidance and worked examples together in one place. The FCA intends to consult on it in Q1 2027 and publish the final version by 3 April 2027.
Although the new regime aims to streamline reporting and remove unnecessary complexity, the regulator has made clear that standards will not slip. Transaction reports remain a vital input for market monitoring, market abuse surveillance and wider supervision, so firms must still deliver accurate, complete and consistent data.
Consistency is a recurring theme throughout CP26/34, with the FCA keen to ensure the new rules are applied uniformly both during and after the transition.
The operational burden should not be underestimated. Reporting reform programmes typically involve complex dependencies across data, systems and teams.
With draft schema and validation rules already published, firms have the tools to begin impact assessments now. Outsourcing reporting offers no escape, as accountability for accuracy, completeness and timeliness stays with the firm.
A structured review can help surface problems early. Firms should assess how the new rules affect existing processes, controls and governance, and map current reporting fields against the proposed schema and validation requirements to identify data gaps. Reporting platforms, workflows and interfaces will need evaluating, while ownership, escalation, exception management and reconciliation processes should be tested. Bringing compliance, operations, technology, front office and reporting teams together into a coordinated programme will be essential, as will tracking further FCA publications.
Crucially, success will depend on more than a technology upgrade. Clear governance, documented reporting decisions, rigorous testing and continuous oversight of data quality will all be required.
By the time the final TRUP lands in April 2027, firms should already be well advanced in gap analysis, operating model design and technology planning. Those that use the staggered timetable wisely can expect fewer surprises, lower implementation risk and a smoother transition when the new regime takes effect. Those that delay may face late-stage remediation, testing bottlenecks and reporting defects.
Read the full ACA Group post here.
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