Preparing for FCA Transaction Reporting Changes by April 2028

The Financial Conduct Authority opened a consultation on October 2, 2026 on guidance and transitional rules for the new UK transaction reporting regime, which takes effect on April 3, 2028 and closes to comment on November 6.

The FCA transaction reporting changes affect investment firms, operators of trading venues, approved reporting mechanisms (ARMs) and other market participants that submit transaction reports, instrument reference data or order book data. The consultation, CP26/34, tells those firms how the final rules would work in practice. Three areas stand out for compliance and operations teams: who carries reporting responsibility, how client data moves between firms, and what happens to historical records.

The paper follows Policy Statement PS26/15, published on August 3, 2026, which set the final rules. Firms that run reporting on spreadsheets, legacy reconciliations or vendor feeds will need to decide how each of those handles the new requirements before the old formats close.

FCA Transaction Reporting Changes: What CP26/34 Proposes

CP26/34 proposes guidance on the new rules, transitional provisions and amendments to the Handbook and technical standards that refer to MAR 13, MAR 14 and MAR 15. It also carries relevant parts of the FCA’s existing Level 3 materials into a new Transaction Reporting User Pack.

The FCA has published draft schemas and validation rules on its Market Data Processor webpage so firms can start assessing system changes. It plans to consult on the User Pack in the first quarter of 2027 and to publish the final version by April 3, 2027.

PS26/15 responded to consultation CP25/32, which ran from November 21, 2025 to February 20, 2026, and followed discussion paper DP24/2. It cut the number of reportable fields from 65 to 52 and removed reporting obligations for about 7 million instruments tradeable only on EU trading venues. It also took foreign exchange derivatives out of scope, which affects more than 400 UK firms.

The default back-reporting period falls from five years to three, which the FCA said will reduce transaction reports needing resubmission by about a third. The regulator estimates the package will cut reporting costs by more than £100 million a year.

Who Carries Reporting Responsibility Under the New Regime

The proposed guidance asks firms to look at the supervisory, governance and operational arrangements around a trade when deciding whether it was executed through a UK branch. Relevant factors include who supervises investment and execution decisions, which branch receives the order and whose trading-venue membership supports execution.

Physical location alone does not settle the question. The consultation gives the example of a New York trader working temporarily in London while staying under New York supervision and mandate. Firms should document which entity and branch keep responsibility and the basis for the reporting decision.

Reporting logic therefore has to reflect how desks actually operate. A change in supervision or branch mandate could mean compliance and operations teams must revisit the assumptions that feed their reports.

Client Data Exchange Between Firms Gets Written Terms

A trade between two investment firms can create reporting obligations for both. PS26/15 introduced optional conditional single-sided reporting, under which one firm submits the report if the other supplies the required information and meets the framework’s conditions.

The framework requires a written agreement that sets, at a minimum, the deadline for supplying that information. The FCA’s guidance says the agreement should be in place before trading starts.

CP26/34 explains how trading capacity determines whose identity appears in the report. Where the sending firm acts as principal, the receiving firm identifies that firm as buyer or seller. In other capacities, it identifies the relevant clients.

For orders with several client allocations, the sending firm must supply the quantity for each client. The receiving firm must identify the original sending firm, even when another intermediary passes the information along. Managers using the framework must supply client details and quantities within the agreed deadline. The guidance does not prescribe a new method for allocating execution prices across funds.

The receiving firm combines the sending firm’s information, such as client identities and allocations, with execution details from its own records. The sending firm stays accountable for the accuracy and completeness of what it supplies, unless the receiving firm’s actions cause the error. If the sending firm misses a condition, such as the information deadline, the guidance says it should report the transaction itself.

That split matters when a firm investigates a bad report. It has to establish whether the failure arose in the supplied client data or in later processing. Teams that already work through the data silos in their compliance stacks will recognize the problem of tracing a field back to its source.

FCA Transaction Reporting Changes and Reference Data

Firms that want relief early depend on reference data. The FCA has said it will not take action against firms that stop reporting instruments tradeable only on EU venues during implementation. Firms that use the FCA’s Financial Instrument Reference Data System (FIRDS) to identify reportable instruments may keep generating reports while those instruments remain in the dataset.

Subject to legislative changes, the FCA is considering removing those instruments from FIRDS before April 2028. Firms and reporting providers would then need to align their scope decisions with the changed reference-data population.

Package transactions add a further data requirement. They replace the previous complex-trade concept and need not share one price or execute at the same time. Firms must link reportable legs through a common package identifier, including where only one leg requires reporting.

Systems therefore need to keep the relationship between transactions negotiated under one economic agreement. Individual trade records and execution timestamps may not hold enough information to rebuild that link later. Vendors of regulatory reporting software, such as OneSumX and Suade Labs, sit in the same market as ARMs and in-house builds for this work.

Historical Records Through the April 2028 Switch

From April 3, 2028, FCA systems will stop accepting the existing formats under UK MiFIR. HM Treasury has committed to repeal the UK MiFIR transaction reporting rules, which date from 2018, and the FCA’s new framework in its Handbook replaces them.

Under the proposed transitional provisions, firms could keep historical records in their original format. Corrections submitted after implementation would follow the new requirements, including corrections to transactions reported before the change.

The FCA would not require information that firms had no obligation to supply when the transaction took place. Firms would still need to retrieve old records and translate them into an acceptable submission. Testing that process would show whether mappings and retained source data remain usable once legacy reporting systems close.

The three-year default back-reporting period from PS26/15 bears on the same question, because it sets how far back a correction or resubmission is likely to reach. Firms that rely on regulatory change tools, such as CUBE Global, to track rule updates will still need their own records to support the translation.

What Comes Next for Firms and Reporting Providers

Responses to CP26/34 are due by November 6, 2026, and can be sent through the FCA’s online form, by email or by post to its Transaction and Position Reporting Team. Firms can use the consultation to flag scenarios the proposed examples leave unresolved, including allocation failures, package identification and corrections that depend on historical records.

The FCA applies a flexible supervisory approach to some areas from August 3, 2026 until the regime starts. The consultation on the Transaction Reporting User Pack follows in early 2027, with the final version due by April 3, 2027, a year before the old formats close.