The FCA has moved its 2028 transaction-reporting overhaul from policy design into technical preparation. On 2 October it published draft transaction-reporting and instrument-reference-data schemas and validation rules, alongside a consultation on guidance, transition and consequential amendments.[3][4]
The rules finalised in August take effect on 3 April 2028. Their narrower scope removes FX derivatives and about seven million EU-only instruments, while fewer report fields and a shorter normal correction lookback reduce the data firms must maintain and resubmit under this regime.[1][2]
Final policy changes
| Area | Current / previous position | 2028 position |
|---|---|---|
| Report fields | 65 | 52Source 1Source 2 |
| FX derivatives | Within transaction-reporting scope where applicable | Removed from the new regimeSource 1Source 2 |
| EU-only instruments | Broader inherited scope | About 7m instruments removedSource 1Source 2 |
| Default back-reporting period | 5 years | 3 yearsSource 1Source 2 |
| Effective date | Existing UK MiFIR regime | 3 April 2028Source 2Source 4 |
Estimated industry economics
| Measure | Value | Context |
|---|---|---|
| Current annual cost | £493m | FCA estimate for the existing MiFID transaction-reporting regime.Source 1 |
| Estimated future cost | About £385m | Expected after the final changes.Source 1 |
| Net annual saving | £108m | Difference between the FCA estimates.Source 1 |
| EU-only instrument saving | About £32m | Attributed to removing approximately 7m instruments from scope.Source 1 |
| Firms affected by FX removal | More than 400 | FCA estimate of firms benefiting from removing FX derivatives.Source 1 |
The FCA’s £108 million estimated annual saving is about 22% of its £493 million estimate for the current regime. The £32 million attributed to removing EU-only instruments forms part of that total. More than 400 firms are expected to benefit from the FX change; each firm’s saving will depend on its transaction mix and the cost of adapting its systems.[1]
Draft schemas turn policy into a testable reporting design
The October files give investment firms, venues and approved reporting mechanisms the draft message structure and validation logic for system design. A reporting build connects instrument eligibility to field mapping, submission, rejection handling and reconciliation. Venues also need to account for the instrument-reference and order-book requirements relevant to their submissions.[3][4]
Technology vendors and control functions will need to version the existing and future logic together, including correction periods and evidence retention. Guidance, transitional provisions and Handbook references are still being consulted on, so the legal policy, technical schemas and final User Pack need to be read as complementary parts of the implementation package.[2][4][3]
Implementation sequence
| Milestone | Date | Status |
|---|---|---|
| Final policy statement | 3 August 2026 | Rules and policy decidedSource 2 |
| Draft schemas and validation | 2 October 2026 | Published for planningSource 3 |
| Implementation consultation closes | 6 November 2026 | Guidance and transition feedback dueSource 4 |
| Transaction Reporting User Pack consultation | Q1 2027 | PlannedSource 4 |
| Final User Pack | By 3 April 2027 | Planned publicationSource 4 |
| New regime | 3 April 2028 | Effective dateSource 2Source 4 |
FX firms need a reporting map for each obligation
The removal applies to the transaction-reporting framework in PS26/15. UK EMIR trade reporting, applicable position reporting, venue records and internal surveillance each retain their own scope. For an FX broker, the practical task is to remove the relevant UK MiFIR submission while maintaining every other reporting and control path that the trade still requires.[2]
The consultation closing on 6 November gives firms a route to identify ambiguous mappings and missing examples before the final transition package and User Pack. Those documents will resolve how the draft technical design is used through the cutover to 3 April 2028.[4][3]
Sources & further reading
- FCA finalises rules to cut transaction reporting costs by over £100m a year Financial Conduct Authority · 3 Aug 2026 · Accessed 16 Oct 2026
- PS26/15: Improving the UK transaction reporting regime Financial Conduct Authority · 3 Aug 2026 · Accessed 16 Oct 2026
- Market Data Processor: draft 2028 schema files and validation rules Financial Conduct Authority · 2 Oct 2026 · Accessed 16 Oct 2026
- CP26/34: Preparing for the new transaction reporting regime Financial Conduct Authority · 2 Oct 2026 · Accessed 16 Oct 2026