FCA consults on guidance and cutover for its April 2028 transaction-reporting regime

On 2 October the Financial Conduct Authority (FCA) opened a consultation on guidance and transitional rules for its replacement transaction-reporting regime. The new rules, MAR 13, 14 and 15, were set out in policy statement PS26/15 and take effect on 3 April 2028. CP26/34 closes on 6 November.

The consultation follows the Treasury’s plan to repeal the UK MiFIR transaction-reporting legislation. The FCA says this will allow a streamlined framework that “will cut costs while ensuring effective regulatory oversight”. Alongside the paper, the FCA has published its draft schema and validation rules on the Market Data Processor webpage. It will announce when they can be tested in the MDP industry test environment.

Worked examples for the changes

The draft guidance concentrates on areas where PS26/15 changed the rules:

• Client indicator: MAR 14 fields 8 and 17 replace the RTS 22 “country of the branch” fields for buyer and seller. Examples cover dealing on own account to fill a client order, matching two client orders, and executing with another reporting firm. In each case the assessment is made from the executing entity’s point of view.
• Conditional single-sided reporting (CSSR): the guidance sets out what a sending firm must give a receiving firm, how allocations work, and how to fill fields 25 and 26, the sending-firm identification codes. If the sender acts as principal it is reported as buyer or seller. In matched principal or any other capacity, its client or clients are reported instead.

The FCA also asks where the current Level 3 materials fail to cover real reporting scenarios. It wants respondents to describe the scenario, the product and the guidance they need. Those responses will feed a full Transaction Reporting User Pack, to be consulted on in Q1 2027.

The cutover

Proposed transitional provisions in MAR TP 5 set out how the switch would work over the weekend:

• Old regime: transactions executed between 00:00:00 UTC on 31 March 2028 and 23:59:59 UTC on 2 April 2028 can be reported under UK MiFIR if submitted before 3 April.
• New regime: transactions executed in that window but submitted on or after 3 April should be reported under the new rules.
• Corrections: from 3 April, firms should comply fully with MAR 13–15, including when correcting reports originally submitted under the old regime.

The FCA has said it will take a flexible supervisory approach to instruments tradeable only on EU venues during the implementation period. It acknowledges that this gives limited relief to firms that use FCA FIRDS to set their reporting scope. It is therefore considering, subject to the Treasury changing the underlying legislation, removing EU-only instruments from FCA FIRDS before 3 April 2028. Question 13 asks for views.

Why it matters

For reporting teams and ARMs, this is the first point at which the new UK regime can be built against a published schema and practical examples, not just policy text. Two areas need early attention:

• CSSR: this is the biggest operational change. Sending and receiving firms will have to agree data flows and field ownership, which in practice means reviewing contracts and specifications with counterparties.
• FIRDS scope: removing EU-only instruments from FCA FIRDS would shrink the UK reportable universe in one step. Reference-data and eligibility logic would have to change with it.

Both should be on 2027 project plans.

Sources

• FCA, CP26/34 web page, 2 October 2026 — https://www.fca.org.uk/publications/consultation-papers/cp26-34-preparing-new-transaction-reporting-regime
• FCA, CP26/34 consultation paper (PDF) — https://www.fca.org.uk/publication/consultation/cp26-34.pdf