The Financial Conduct Authority (FCA) has formally released Consultation Paper CP26/34, providing the industry with the technical and transitional roadmap required to migrate toward the UK’s new, streamlined transaction reporting framework. Following the policy foundations laid out in PS26/15, this consultation serves as an operational blueprint for investment firms, trading venues, and Approved Reporting Mechanisms (ARMs).
With the absolute go-live date set for 3 April 2028, firms must shift focus from policy interpretation to system-architecture planning and data-lineage mapping.
1. Architectural Consolidation: The New Transaction Reporting User Pack
Historically, firms have relied on a fragmented mix of FCA Handbook rules, European non-legislative guidelines, and legacy “Level 3 Materials”. CP26/34 proposes a critical consolidation:
- The Blueprint: The FCA will migrate and rewrite relevant parts of existing Level 3 guidance into a single, cohesive Transaction Reporting User Pack.
- Scope: This unified resource will govern all core interpretations of transaction reporting, instrument reference data, and order record-keeping requirements.
- Timeline: The regulator plans to consult on the full draft of the User Pack in Q1 2027, with the final text scheduled for publication by 3 April 2027, exactly one year ahead of implementation.
2. Immediate Systems Readiness: Validation Rules and Schema Release
Firms cannot afford to adopt a “wait-and-see” approach until 2028. Alongside CP26/34, the FCA has concurrently released its draft transaction reporting schema and Market Data Processor (MDP) validation rules.
- For RegTech architects and engineering teams, these artifacts provide the exact technical specifications needed to build out data validation pipelines, handle structural changes resulting from the removal of certain asset classes (e.g., the exclusion of FX derivatives), and test schema compatibility on the MDP platform.
3. Consequential Handbook Realignment: MAR 13, 14, and 15
To legally anchor the transition away from the repealed EU MiFIR legislative framework, the FCA is introducing sweeping consequential amendments. The consultation explicitly maps out revisions to the Handbook and Technical Standards to properly cross-reference MAR 13 (Record Keeping), MAR 14 (Transaction Reporting), and MAR 15 (Instrument Data Reporting). This realignment updates cross-regime dependencies, ensuring that market abuse surveillance data pipelines remain uninterrupted.
4. Transitional Provisions & Interim Supervisory Posture
Managing a hard cutover on 3 April 2028 presents significant operational risks. To mitigate this, the FCA is deploying an active interim supervisory framework:
- Immediate Relaxations: A flexible supervisory approach is already underway for specific areas. Most notably, the reduced 3-year back-reporting window is active immediately, lowering historical remediation burdens.
- The Transition Runway: CP26/34 outlines precise transitional provisions designed to prevent dual-reporting bottlenecks, giving firms a structured mechanism to migrate open positions and active reporting lines into the new framework without duplicating data packets.
5. Supervisory Flexibility:
Because the finalized rules streamline and reduce the reporting burden (such as dropping the reportable fields from 65 down to 52), the FCA announced that it will apply a flexible supervisory approach. This means that the FCA will not take enforcement action against firms that choose to implement specific regulatory relief earlier than the mandatory deadline. Firms can reduce burden by implementing the below prior to the April 2028 deadline:
- EU-only instruments: Firms do not need to report transactions for financial instruments that are exclusively tradeable on EU trading venues.
- FX Derivatives: Firms are exempt from reporting foreign exchange derivatives under MiFIR, provided they are already complying with UK EMIR reporting requirements for those instruments.
- Phased-out fields: The FCA will not penalize firms or require “errors and omissions” notifications if they fail to populate specific transaction reporting fields that are being eliminated from the schema
6. FIRDS as the ‘Golden Source’:
Previously, firms had to reconcile their internal transaction scopes against both the FCA FIRDS and ESMA FIRDS databases to determine if an execution was reportable.
- Under the incoming MAR 15 updates, FCA FIRDS becomes the sole “golden source” for validating whether an instrument is subject to UK MiFIR transaction reporting.
- This significantly simplifies the logic for RTS1 and RTS2 determination; if an ISIN is not active in the FCA’s standalone database, it does not carry a reporting requirement under the UK regime
Under the previous EU-aligned framework, an instrument was deemed reportable if it was Traded on a Trading Venue (ToTV) anywhere across the EU or UK. With the new FIRDS changes:
- RTS1: Instruments that are exclusively tradeable on EU venues are being entirely excised from the scope of UK transaction reporting. FCA FIRDS will stop verifying or requiring data for these instruments.
- RTS2: The elimination of EU-only instruments and the wholesale removal of foreign exchange (FX) derivatives drastically reduce the universe of complex derivatives that firms previously had to report under the RTS2 data standard
Next Steps for Compliance Leadership
The consultation period for FCA CP26/34 closes on 6 November 2026.
For RegTech specialists and institutional compliance officers, the immediate priority is conducting a delta analysis between current MiFIR reporting pipelines and the newly issued draft MDP schema. Gaps in transaction data scenarios or edge cases should be escalated through formal responses before the November deadline to ensure the upcoming User Pack accommodates complex reporting arrangements.
Source: FCA CP26/34
About the Authors
Rajesh Gupta & Gopi P.D.
Regulatory Reporting Subject Matter Experts | Reg-X Innovations
This article was jointly authored by Rajesh Gupta and Gopi P.D., drawing on their expertise in regulatory reporting, data quality, reporting controls and regulatory implementation.
Is Your Transaction Reporting Ready for April 2028?
The transition to the new UK MiFIR reporting framework requires more than adapting to revised reporting requirements. Firms need to assess their reporting logic, data mappings, validation processes and existing controls to identify potential gaps ahead of implementation.
Reg-X can help you prepare. Our regulatory reporting specialists work with financial institutions to assess reporting challenges, identify gaps and strengthen reporting controls.
If your team is evaluating the impact of these changes, use the form below to speak with our experts or email us at [email protected]. Let’s discuss your current reporting setup, the challenges you’re facing and how Reg-X can support your transition.
