FCA Publishes Consultation Paper on Improving the UK Transaction Reporting Regime

The Financial Conduct Authority (FCA) has published Consultation Paper CP25/32: Improving the UK transaction reporting regime, outlining proposed changes to streamline transaction reporting requirements and enhance market integrity. Transaction reports are essential for detecting market abuse, preventing financial crime, monitoring market functioning and supporting regulatory supervision and crisis responses.

This consultation is relevant to MiFID investment firms, credit institutions, trading venue operators, Systematic Internalisers, Approved Reporting Mechanisms, trade repositories, market data providers and any other firms or advisers involved in UK transaction reporting.

Key Proposals in CP25/32

Reducing Reporting Fields and Obligations

The FCA proposes to reduce the number of transaction reporting fields from 65 to 52.

FX derivatives and 6 million EU-only tradeable instruments would be removed from the reporting scope, easing the burden for over 400 UK firms.

Systematic internalisers would no longer be required to submit instrument reference data, eliminating unnecessary duplication.

Simplifying Back Reporting and Data Requirements

The default back reporting period would reduce from five to three years.

Trading venues would populate fewer fields, simplifying reporting for over 1,700 international firms accessing UK markets.

Instrument reference data fields would reduce from 48 to 37, streamlining the data set.

Regulatory Clarity and Data Quality

CP25/32 seeks to improve the clarity of reporting requirements, enhancing reporting efficiency, data quality and regulatory oversight.

The existing EU technical standards (RTS 22, RTS 23 and RTS 24) would be replaced with new FCA rules within the Market Conduct sourcebook (MAR) of the FCA Handbook.

Proportionality and Cost Reduction

The FCA aims for proportionate regulation, aligning firms’ reporting obligations with regulatory benefits.

Estimated cost savings for firms could exceed £100 million annually, supporting growth, competition and market integrity.

What This Means for Firms

Firms should review the proposed changes carefully to determine which transaction reporting obligations will apply to them going forward. Early assessment is essential to ensure continued compliance and reduce the risk of reporting errors.

Systematic internalisers and trading venues, in particular, may need to update systems, controls and reporting processes to account for the reduced number of data fields and revised requirements. This may involve adjustments to operational workflows, governance arrangements and technology infrastructure.

All firms should assess the readiness of their internal systems to ensure that reporting remains accurate, timely and compliant once the new rules come into force. Proactive planning, including testing and validation, will help minimise disruption and support a smooth transition to the updated regime.

Conclusion

CP25/32 signals the FCA’s intent to create a more efficient, proportionate and data-driven transaction reporting framework. Firms already engaged in or planning UK market activity should review reporting obligations and internal processes to ensure compliance, reduce unnecessary costs and support market integrity. Proactive preparation will allow firms to navigate the transition smoothly and capitalise on operational efficiencies.

How Complyport Can Help?

At Complyport, we help firms manage evolving regulatory reporting requirements by:

Assessing Transaction Reporting Impact: We review your existing reporting processes to identify gaps, inefficiencies and exposure to upcoming FCA obligations. By benchmarking current practices against new requirements, we provide a clear picture of where adjustments are needed, helping you mitigate risk and avoid potential regulatory breaches.
Operational Planning and Compliance Strategy: Our team models the impact of proposed reporting changes, including reductions or modifications, on your operations. We help design a strategy that aligns your systems, workflows and internal controls with the new requirements, ensuring smooth implementation and minimal disruption
Governance and Documentation: We assist in updating internal procedures, compliance manuals, and reporting frameworks to reflect the latest regulatory expectations. This includes embedding clear responsibilities, escalation processes and audit trails, so your firm can demonstrate both compliance and operational robustness.
Training and Ongoing Support: Regulatory requirements are only as effective as the people implementing them. We deliver bespoke training programmes for Compliance teams, Operations, and Senior Management, ensuring that all stakeholders understand their roles and responsibilities. Our ongoing support ensures your reporting practices remain aligned with evolving FCA expectations over time.