The Financial Conduct Authority has opened a consultation on the practical move to the United Kingdom’s new transaction-reporting regime, giving affected firms until 6 November to respond.
The consultation, CP26/34, does not reopen the core policy decisions already made for the new regime. Instead, it focuses on the guidance, technical changes and transitional arrangements intended to help market participants apply those rules consistently when they take effect on 3 April 2028.
Focus on the move to the new system
Transaction reports are an important source of information for the regulator’s monitoring of financial markets, market-abuse surveillance and supervisory work. The new framework is intended to replace the existing UK MiFIR transaction-reporting legislation with rules set out in the regulator’s Handbook.
The latest proposals address the less visible but consequential work of making that change operational. They include guidance on changes made in the new rules, consequential amendments to the Handbook and Technical Standards, and provisions designed to clarify how the old and new arrangements would meet at the point of transition.
That distinction matters. A consultation on implementation is not the same as a new set of final reporting requirements. But the detail of definitions, data fields, validation and handover arrangements can determine whether firms submit comparable information and whether the regulator can continue to use it effectively.
Draft technical material is now available
Alongside the consultation, draft schema files and validation rules have been published for transaction reporting and instrument-reference data. The materials are intended to give firms early visibility of the proposed technical requirements ahead of the 2028 implementation date.
For firms that report directly, through an approved reporting mechanism or via a trading venue, that early visibility creates an opportunity to identify where systems, controls and data flows may need work. It does not mean the draft material is final. Responses to the consultation can still shape guidance and the arrangements used for the transition.
The proposals are relevant to investment firms, operators of trading venues, approved reporting mechanisms, trade associations and other participants that submit transaction reports, instrument-reference data or order-book data. Different organisations will have different responsibilities, but a shared technical framework makes it easier for data to be received and assessed consistently.
Transition questions need practical answers
One central issue is how reports and reference data should be handled around the implementation date. Transactions can be executed under one framework and reported, corrected or reconciled after another has begun. Record-keeping duties can also extend beyond a single reporting day. Clear transitional provisions are therefore intended to reduce uncertainty over those boundary cases rather than simply set a date on a calendar.
The consultation also proposes changes to keep cross-references in the Handbook and associated standards aligned with the new structure. In particular, the proposals refer to new areas covering record keeping, transaction reporting and financial-instrument reference data. Such amendments may appear administrative, yet inaccurate references can create avoidable uncertainty for compliance and technology teams.
What happens next
Responses are due by 6 November. The regulator has said it plans a further consultation on a new Transaction Reporting User Pack in the first quarter of 2027, followed by a final version by 3 April 2027. That pack is intended to bring relevant guidance, clarifications and reporting examples together in one place.
For now, the 3 April 2028 commencement date remains the stated timetable for the new rules, rather than an immediate change to reporting obligations. The consultation gives the market a defined period to test whether the proposed guidance and transition arrangements are clear enough before technical implementation gathers pace.
