The FCA’s CP25/32 delivers the most significant transaction reporting reset in decades

This isn’t just about minor rule changes; it represents a fundamental overhaul that aims to save the industry over £100 million annually while maintaining the integrity of the UK market. Firms that treat this as a compliance-only exercise will miss the opportunity. We see this as a mandate to embrace a data-centric and streamlined future.

Here is our analysis of the key shifts and how we are advising clients to prepare now for the expected 18-month implementation window.

The strategic shift: a framework for growth

The FCA is laying the groundwork for a long-term, harmonised future, moving away from the complex, post-Brexit patchwork.

1. Embracing proportionality: the golden source and de-scoping

The FCA is aligning regulatory cost with supervisory benefit by reducing the burden in areas seen as having low utility:

• Geographic scope: the proposal to remove reporting obligations for instruments solely tradeable on EU trading venues is a major win for UK market focus and simplicity. This removes the reporting requirement for approximately 6 million financial instruments.
• OTC derivatives: the plan to remove FX derivatives from the reporting scope indicates a reliance on UK EMIR data for risk monitoring, eliminating duplication where MiFIR data offered limited added value for market abuse surveillance.
• FIRDS as a ‘golden source’: allowing firms to treat the FCA’s Financial Instrument Reference Data System (FCA FIRDS) as the primary “golden source” for determining reportability will simplify compliance logic and reduce reliance on expensive third-party data or complex internal processes.

2. A long-term vision for harmonisation (MiFIR/EMIR/SFTR)

While a “report once” single template is not happening now, the FCA and the Bank of England are pursuing a gradual, principled transition towards a streamlined and harmonised framework across MiFIR, EMIR, and SFTR.

The three core principles underpinning this approach are critical for any forward-looking data strategy:

• Data should only be collected where needed.
• A firm should only report data once.
• Data should be shared where appropriate.

This confirms that regulatory data architecture needs to anticipate multi-regime reporting simplification and data sharing utility in the years ahead.

Key tactical changes: time to future-proof systems

Beyond the strategic scope changes, several field and process updates will require immediate attention from IT and Operations teams to capitalise on the estimated £115.3 million in annual ongoing cost savings.

Translation structure

The proposal is to reduce the total fields from 65 to 52 and instrument reference data fields from 48 to 37. 

Impact for IT and data teams: it would streamline data flows, rationalise redundant fields (e.g., Option Type/Exercise Style/Delivery Type redundant to CFI code).

Data quality and compliance

The FCA proposes to reduce the default back reporting period from 5 years to 3 years.

Impact for IT and data teams: immediate reduction in data retention/resubmission obligations. Focus remediation efforts on the 3-year window for most errors.

Client identification

Conditional Single-Sided Reporting (CSSR) is proposed across all trading capacities (not just RTO).

Impact for IT and data teams: this opens up significant operational efficiencies for buy-side firms by allowing dealers/brokers to report on their behalf, significantly reducing volume and client-side system burden.

Trading capacity

The FCA proposes to add a new value ‘DEAU’ to RTS 22 Field 59 (execution within firm) for Direct Electronic Access (DEA) to close a current surveillance gap.

Impact for IT and data teams: this will require minor schema update, but critical for managing compliance around market abuse monitoring for DEA providers.

Package transactions

The proposal is to replace ‘complex trade’ with ‘package transaction’ definition aligned with UK EMIR, and introduce new fields to report both the package price and the single-leg price.

Impact for IT and data teams: new fields are required. Crucial for harmonising inter-regime reporting logic and enhancing market abuse surveillance of bundled trades.

Branch/client data

The proposal is to remove five ‘Country of Branch’ fields and replace them with simpler ‘Client Indicator for the Buyer/Seller’ (True/False).

Impact for IT and data teams: this would reduce the burden of reporting sensitive or difficult-to-source branch PII while retaining critical oversight of the client relationship.

Compliance note: accountability and the role of ARMs

Amidst the discussion of structural reforms, the FCA delivered a key clarification regarding reporting accountability. It explicitly reiterates that only an investment firm, trading venue, or ARM may submit transaction reports. Crucially, for those outsourcing the function, the investment firm remains responsible for the overall completeness, accuracy, and timely submission of the data, regardless of any arrangement with an unregulated third party or vendor. This underscores the enduring necessity for robust internal systems and controls.

Conclusion: act now to position for the future

The FCA’s proposals are a clear statement: they are committed to a modern, efficient, and competitive UK regulatory environment. This is an invitation to the industry to move beyond minimal compliance and build truly intelligent reporting infrastructures.

To demonstrate leadership and achieve maximum benefit, firms must:

1. Prioritise roadmap revisions: Integrate the removal of deprecated fields and the implementation of the new CSSR and Package Transaction fields.
2. Rethink data strategy: assess how the “report once” principle affects existing internal data flows and explore how being early on the ‘golden source’ approach can reduce dependencies.
3. Engage with the consultation: respond to the FCA by 20 February 2026 to ensure implementation details support your business model and operational readiness.