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FCA’s draft schemas prepare firms for the 2028 transaction-reporting overhaul

Final rules will remove FX derivatives and reduce reports from 65 fields to 52 from 3 April 2028. October’s draft schemas support system preparation while guidance and transition proposals remain open for comment until 6 November.

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]

Before & after01

Final policy changes

Final policy changes
AreaCurrent / previous position2028 position
Report fields6552Source 1Source 2
FX derivativesWithin transaction-reporting scope where applicableRemoved from the new regimeSource 1Source 2
EU-only instrumentsBroader inherited scopeAbout 7m instruments removedSource 1Source 2
Default back-reporting period5 years3 yearsSource 1Source 2
Effective dateExisting UK MiFIR regime3 April 2028Source 2Source 4
Key numbers02

Estimated industry economics

Estimated industry economics
MeasureValueContext
Current annual cost£493mFCA estimate for the existing MiFID transaction-reporting regime.Source 1
Estimated future costAbout £385mExpected after the final changes.Source 1
Net annual saving£108mDifference between the FCA estimates.Source 1
EU-only instrument savingAbout £32mAttributed to removing approximately 7m instruments from scope.Source 1
Firms affected by FX removalMore than 400FCA 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]

Event timeline03

Implementation sequence

Implementation sequence
MilestoneDateStatus
Final policy statement3 August 2026Rules and policy decidedSource 2
Draft schemas and validation2 October 2026Published for planningSource 3
Implementation consultation closes6 November 2026Guidance and transition feedback dueSource 4
Transaction Reporting User Pack consultationQ1 2027PlannedSource 4
Final User PackBy 3 April 2027Planned publicationSource 4
New regime3 April 2028Effective 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]

Follow the evidence

Sources & further reading

  1. FCA finalises rules to cut transaction reporting costs by over £100m a year Financial Conduct Authority · 3 Aug 2026 · Accessed 16 Oct 2026
  2. PS26/15: Improving the UK transaction reporting regime Financial Conduct Authority · 3 Aug 2026 · Accessed 16 Oct 2026
  3. Market Data Processor: draft 2028 schema files and validation rules Financial Conduct Authority · 2 Oct 2026 · Accessed 16 Oct 2026
  4. CP26/34: Preparing for the new transaction reporting regime Financial Conduct Authority · 2 Oct 2026 · Accessed 16 Oct 2026

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