Transaction reporting
Also called miFIR transaction reporting, article 26 reporting
Transaction reporting is the duty on investment firms to send regulators a detailed record of each trade in a reportable financial instrument. Under MiFIR the report goes to the national regulator no later than the close of the following working day. Regulators use the data to detect market abuse and monitor markets.
How it works
A firm captures each executed trade with its instrument, price, quantity, time, buyer, seller and the people or algorithms that made the decision. Clients are identified by legal entity identifiers or national identifiers. Most firms route reports through an approved reporting mechanism, which validates them and passes them to the regulator. Rejected reports are corrected and resubmitted, and firms reconcile front office records against what the regulator received.
Regulators run surveillance across these reports to spot insider dealing and manipulation. Errors and missing reports are a regular source of fines because they weaken that surveillance. In the UK, the FCA's PS26/15 cuts reportable fields from 65 to 52, removes instruments traded only on EU venues and shortens the default back reporting period from five to three years from 3 April 2028.
The rules
Firms report complete and accurate details of transactions to the competent authority no later than the close of the following working day.
Investment firms executing transactions in reportable instrumentsReplaces UK MiFIR reporting with FCA rules, cutting fields from 65 to 52 and removing FX derivatives and EU-only instruments from scope.
Investment firms, trading venues and approved reporting mechanismsRequires a consolidated audit trail that tracks orders and trades in US equities and options across their full life cycle.
US exchanges and broker-dealers in NMS securities and listed optionsCommon questions
What is the deadline for a MiFIR transaction report?
Under Article 26 of MiFIR, firms report each transaction as quickly as possible and no later than the close of the following working day. This is often called T+1 reporting. Late reports are treated as breaches and are usually picked up through data quality checks run by the regulator.
What is an approved reporting mechanism?
An approved reporting mechanism, or ARM, is an authorised service that submits transaction reports to the regulator on behalf of firms. It validates reports against the regulator's rules before passing them on. The reporting firm keeps responsibility for accuracy even when it uses an ARM.
What changes in UK transaction reporting in 2028?
The FCA's PS26/15 applies from 3 April 2028. It reduces reportable fields from 65 to 52, removes FX derivatives and instruments traded only on EU venues, exempts most corporate actions and shortens the default back reporting period from five to three years.
How is transaction reporting different from trade reporting?
Trade reporting makes trade details public shortly after execution to support price transparency. Transaction reporting is confidential and goes only to the regulator. It contains far more detail, including client and decision maker identifiers, to support market abuse surveillance.
Our coverage
News and analysis on regulatory reporting from RegTech Post.
Read the coverage →RegTech PostPreparing for FCA Transaction Reporting Changes by April 2028Read the article →RegTech PostMiFID II Overview: Key Rules and the Digital Tools Driving ComplianceRead the article →
