The FCA receives more than 7bn transaction reports every year, using the data to detect market abuse, support financial crime investigations and monitor market integrity. However, the regulator also recognises that the current MiFIR transaction reporting regime is complex and costly. 

CP25/32 proposes a significant overhaul, replacing the retained MiFIR firm-facing rules with a new FCA handbook framework designed to be more proportionate, streamlined and easier to update. 

Why is the FCA replacing MiFIR transaction reporting rules?

Think of it like relocating the instruction manual for a critical system: the business process (transaction reporting) still exists, but the authoritative source of requirements changes, moving from retained EU law text to the Handbook and the FCA can update the “manual” more quickly as markets evolve.  

That’s the promise of the transfer. The risk is familiar too: when the manual moves, teams can miss where key obligations landed or assume streamlining means that no action is required. 

What is the implementation timeline?

CP25/32 (Improving the UK transaction reporting regime) opened on 21 November 2025 with the consultation closing on 20 February 2026.  

The FCA plans to publish a Policy Statement in H2 2026, with an implementation period of around 18 months (to be confirmed). It also flags that it will consult on transitional provisions and consequential Handbook amendments in due course. 

Firms with an already busy regulatory change agenda should begin planning early, particularly if multiple programmes are competing for technology, compliance and operational resources.

What the move to the FCA handbook means for firms

Three practical implications stand out: 

1. Your primary compliance reference point shifts 

Today, many operating procedures and control frameworks are anchored around retained MiFIR articles, onshored RTS concepts and FCA guidance. Under the new approach, firms should expect the FCA Handbook to become the central reference point for the detailed firm-facing requirements.  

2. Reduced reporting obligations still create implementation work 

The FCA’s proposals include removing FX derivatives from reporting requirements, affecting more than 400 firms; removing reporting for millions of “EU-only traded” instruments; and reducing the historic error correction and back-reporting period from five years to three years.  

Even when obligations reduce, firms often face a spike in delivery work: data mapping updates, control re-design, ARM interface changes, testing and revising policies and procedures. 

3. The FCA is trying to improve data quality (not just cut cost) 

CP25/32 is clear that transaction reports are critical for market integrity and financial crime outcomes, and it is proposing to remove or adapt requirements it sees as disproportionate while clarifying obligations so it can receive “more accurate and complete reports.”  

So the direction of travel is not lighter touch, it’s cleaner data with clearer rules.

For firms, that means implementation should be viewed as more than a reporting exercise. It is an opportunity to simplify reporting processes, strengthen governance and improve data quality ahead of the new regime.

MiFIR transaction reporting: A practical readiness checklist for firms

Firms do not need to wait for the final rules before preparing. The following actions will help regardless of the final drafting. 

  • Create one end-to-end reporting inventory: Pull into a single view your in-scope activities, reporting flows (venue/SI/OTC and any delegation), key data elements with named owners and vendor/tool dependencies (ARM, trade capture, reference data, surveillance) to form the baseline for the Handbook restructure. 
  • Engage your ARM early on “what changes and when”: Confirm expected schema/validation changes, release and testing timelines, any parallel-run approach and how historic corrections will work under a likely 3-year lookback. 
  • Get your reporting issues under control (ahead of a likely change from a 5-year to a 3-year correction window): You don’t need to change reporting rules yet, but it’s worth tightening how you track and fix errors and missed reports. Agree what “closed” looks like, focus on recurring root causes and set simple MI/escalation triggers so the backlog doesn’t grow during the transition. 
  • Make ownership for reporting quality clear: Without redesigning anything yet, agree who is accountable day-to-day for report accuracy, set a regular review rhythm with Compliance and give senior management a small, consistent set of metrics. Clarity of ownership is what keeps change controlled when the final rules land. 

What should firms watch for next?

Over the coming months, firms should watch for three things from the FCA: 

  • The Policy  Statement (H2 2026): This is where the FCA is expected to confirm the final approach and publish the detailed rules, alongside the timetable for implementation (the FCA has indicated an implementation period of around 18 months, to be confirmed). 
  • Transitional arrangements: The FCA has indicated further consultation “in due course” on how firms move from the current framework to the new Handbook-based requirements including any phasing, grace periods or cutover expectations. 
  • Consequential Handbook changes and supporting materials: As requirements transfer into the Handbook, firms should track any related amendments (definitions, scope, submission instructions) and any updated guidance that affects interpretation and implementation planning. 

In the meantime, firms can use the pre-implementation period to tighten reporting governance, review reporting governance, confirm data ownership and reporting processes and engage ARMs early on anticipated delivery timelines so you are ready to move quickly once the final rules are published.

How fscom can help

Whether you are assessing the impact of CP25/32, planning for the move to the FCA Handbook or reviewing your transaction reporting framework, fscom can help you prepare for implementation with practical, proportionate support. Get in touch to discuss how we can help. 

‘This post contains a general summary of advice and is not a complete or definitive statement of the law. Specific advice should be obtained where appropriate.’