FCA PS26/15: simpler MiFIR transaction reporting, no let-up on data quality
FCA PS26/15 reduces the scope and cost of UK MiFIR transaction reporting, with some supervisory flexibility already available. But the new MAR 14 framework also makes the FCA’s expectations for reporting controls and data quality considerably more explicit.
There is some genuinely good news in the detail of the Financial Conduct Authority’s (FCA) Policy Statement PS26/15. The FCA expects annual savings of more than £100 million for firms. The number of transaction reporting fields will fall from 65 to 52 and around seven million EU-only instruments will no longer be in scope.
But simplification should not be confused with a relaxation of the FCA’s interest in reporting quality. The Policy Statement removes duplication and lower-value data while preserving the information the FCA uses for market surveillance and other supervisory purposes. At the same time, MAR 14 makes the regulator’s expectations for testing, reconciliation, incident management and remediation considerably more explicit.
The result is a regime with fewer reporting requirements, but a clearer expectation that firms can demonstrate control over the reports for which they remain responsible.
A welcome reduction in MiFIR transaction reporting requirements
There is no doubting the scale of the existing burden. The FCA estimates that firms spend £493 million each year meeting UK MiFIR transaction reporting requirements. PS26/15 aims to reduce that cost without compromising the data needed to detect market abuse and supervise firms.
FX derivatives will leave scope, as will instruments that are tradeable only on EU venues. The FCA has also narrowed or clarified several exclusions and reduced the number of fields in the report. The transaction reporting requirements will move into Chapter 14 of the FCA’s Market Conduct sourcebook when the new regime takes effect on 3 April 2028. Those of us who have spent years talking about RTS 22 will have to retrain ourselves. Some habits may prove harder to remove than Fields 61-65.
The direction of travel is broadly positive. However, firms should resist treating PS26/15 as a simple field-mapping exercise. The changes affect reporting scope, reporting logic, the allocation of responsibility and the controls that sit around the reporting process.
What changes before 3 April 2028?
The new rules do not take effect until 3 April 2028, but the FCA has adopted a flexible supervisory approach in selected areas from 3 August 2026. This gives firms an opportunity to realise some of the benefits during the implementation period.
The clearest immediate change concerns back reporting. Three years is now the normal correction horizon unless the FCA instructs a firm otherwise. That should reduce the cost and operational strain of remediation programmes, particularly where an issue affects a large historic population.
It is not, however, a three-year record-retention rule. Firms must continue to retain five years of transaction and order records and the FCA may still require five years of back reporting in exceptional cases. The distinction matters. Firms must still identify issues and assess their impact. They must also retain the evidence required to respond if the FCA asks them to go further.
The FCA has also set out areas where it will not take action during the implementation period. These include certain EU-only instruments, FX instruments where the firm is subject to UK EMIR reporting, some corporate event activity and a defined set of fields and scenarios. The details and conditions differ, so Chapter 6 – Table 1 of the Policy Statement deserves a careful read.
Supervisory flexibility needs a controlled response
For many firms, the first practical question will be which existing processes can be stopped or reduced now. That is a worthwhile exercise. There is little value in preserving expensive manual checks for requirements the FCA has explicitly deprioritised, provided the firm has understood the conditions and the consequences for connected data and controls.
But ‘we will not take action’ is not the same as deleting a field from the current rulebook. In some cases the field must still be populated even though the FCA has said it will not act where firms fail to report it in line with the applicable requirements. In others, the flexibility applies only to firms meeting a particular condition. Firms that continue to report should also consider whether their existing obligations and validation controls still apply.
In practice, firms need an evidence-based decision for each change. Which transactions or fields are affected? What condition permits the change? Which upstream and downstream processes rely on the data? What control will confirm that the firm has applied the flexibility only to the intended population? The saving comes from stopping unnecessary work – not from losing sight of what the reporting process is doing.
What does MAR 14 mean for reporting controls?
Perhaps the most significant part of PS26/15 is not the reduction in fields. It is the level of detail now given to methods, arrangements and incident management in MAR 14.
The core expectations will be familiar to firms with mature control environments. From 3 April 2028, MAR 14 will require regular testing of the reporting process and regular reconciliation of transaction records against samples of reports submitted to the FCA. The accompanying guidance says firms should request their FCA data samples through the Market Data Processor (MDP).
The new guidance also spells out what should happen when something goes wrong. Firms should maintain an incident management framework for assessing reporting errors and understanding their causes. That framework should track remedial action. It should also support internal escalation and FCA notification. The policies and procedures behind it should provide an auditable record of decisions.
None of this will feel revolutionary to firms that have followed the FCA’s Market Watch publications, or invested in a strong control framework. The FCA has taken much of what it has described as good practice over many years and written it into the Handbook in considerably clearer terms.
The FCA has not introduced a materiality threshold for breach notifications. Firms will continue to need a proportionate framework for assessing incidents and deciding if they meet the applicable notification requirements. They must be able to evidence their assessment and internal escalation.
Will CSSR reduce buy-side reporting obligations?
PS26/15 broadens conditional single-sided reporting, or CSSR, and reduces the information a sending firm must provide to a receiving firm. The new model requires four categories of information rather than the ten fields associated with the existing transmission mechanism, together with a written agreement. FCA guidance says the agreement should be in place before the firms transact.
The allocation of responsibility is clearer. The sending firm remains responsible for the accuracy and completeness of the information it supplies. The receiving firm is generally not responsible for an error in that information unless its own action caused the failure.
CSSR is optional and may help some firms. It should not be mistaken for wholesale reporting relief for the buy side. Many firms trade with non-UK counterparties and will still need to maintain their reporting capability. Receiving firms must also choose to offer the service and put the necessary agreements, data flows and controls in place.
It will be interesting to see whether the new model changes market practice. My expectation is that the impact will be useful but limited, rather than the great disappearance of buy-side transaction reporting. I have been wrong before, although naturally I try not to make a habit of documenting the occasions.
What firms should do now to prepare for PS26/15
The FCA plans to publish a draft schema, validation rules and new guidelines in October 2026. Firms therefore do not yet have every technical detail needed for implementation. They do, however, have enough information to begin the work.
A sensible starting point is a clear inventory of the firm’s business activity and the bookings it creates. Firms can then map the reporting obligations that follow. This baseline supports scenario testing and informs both change management and control design. Without it, firms risk changing fields and validations without understanding whether the end-to-end report remains complete and accurate.
Firms should now consider:
- where the FCA’s supervisory flexibility can reduce current remediation or manual processing without creating gaps elsewhere
- which products, instruments and transaction scenarios will move into or out of scope in April 2028
- whether reporting data has clear ownership and traceable lineage across internal systems, venues, approved reporting mechanisms (ARMs) and other vendors
- whether testing and reconciliation cover both reporting completeness and field-level accuracy using FCA data
- whether the incident management framework records assessment, root cause, remediation, escalation and notification decisions in a way that can withstand regulatory scrutiny.
The industry has asked for transaction reporting simplification for years. PS26/15 delivers a meaningful portion of it, and firms should take the opportunity to remove work that no longer serves a regulatory purpose.
The bargain is straightforward. The FCA will ask for less data, but it will continue to expect firms to understand each report and its purpose. Firms must also know whether the data is correct. Fewer fields should make that task easier. They do not make it optional.
Kaizen supports firms with independent transaction reporting testing, issue assessment and control framework reviews. To discuss the impact of PS26/15 on your reporting obligations and assurance programme, please get in touch to arrange a call with Matthew or another of our reporting specialists.
