FCA Imposes £1.1 Million MiFIR
Fine on Sigma Broking

The Financial Conduct Authority (FCA) has imposed a £1,087,300 fine on Sigma Broking Limited, marking the regulator’s second enforcement action under UK MiFIR. The penalty relates to widespread inaccuracies in Sigma’s transaction reporting between 1 December 2018 and 1 December 2023, during which 924,584 reports were found to be incomplete or inaccurate. This represented close to 100 per cent of all transactions handled by the firm during the period. The failings were identified following an FCA alert in May 2023, with Sigma notifying the regulator in January 2024 and confirming the scale of the issue in February 2025 after completing back reporting.

Key Takeaways:

• Significant Increase in Fine Size : The fine issued to Sigma is over ten times larger than the £99,200 penalty levied against Infinox Capital Limited in January 2025. This escalation reflects the FCA’s more assertive stance in calibrating fines based not only on volume but also the duration and systemic nature of reporting failures.

• Systemic Weaknesses and Governance Failures : The core issue stemmed from incorrect system configuration, which remained undetected due to deficiencies in Sigma’s control framework. The firm failed to implement appropriate reconciliation routines, data validation, or governance oversight, allowing the errors to persist over a five-year period without remediation.

• Clear Regulatory Expectations Ignored : The FCA regarded the breach as particularly serious due to a series of aggravating factors. Over several years, the regulator had issued substantial guidance to the industry through sources such as Market Watch, the guidelines, and other industry communications. Sigma had also previously been fined £531,600 in 2022 for failures to report client allocations, which the regulator states should have served as a direct reminder of its obligations. Despite this, Sigma failed to take corrective action. Additionally, the firm commissioned a third-party review in March 2023, but did not inform the FCA of the engagement until June 2023, following regulatory intervention.

• A Data-Led Regulator : The FCA emphasised the strategic importance of transaction reporting data in its final notice:

“The Authority is a data-led regulator. Transaction reporting data sets are an important information source that enable the Authority to conduct effective surveillance and oversight, meet its statutory objective to maintain market integrity, and deliver on prioritised commitments in the Strategy 2025 to 2030 to fight financial crime. In order to be able to monitor and detect market abuse effectively, the Authority needs to receive complete and accurate information in a timely manner regarding the types of instruments traded, when and how they are traded and by whom.”

To learn more about the FCA being a data-led regulator, read our recent article: FCA Strategy 2025-2030: What "Being a Smarter Regulator" Really Means for Firms

Together, the Sigma and Infinox fines signal a new enforcement era under UK MiFIR, one that prioritises data quality, governance, and accountability. Firms must recognise that passive compliance is no longer sufficient and must demonstrate the ability to conduct effective oversight and timely remediation.

At Qomply, our MiFID 101 and Governance training programmes are specifically developed to help firms understand and meet the FCA’s expectations. We support compliance teams in building robust control frameworks, implementing automated reconciliations, and aligning internal processes with best practice standards to mitigate regulatory risk.