FCA’s Consultation Paper

The FCA has released its long-awaited Consultation Paper (CP25/32) on Improving the UK Transaction Reporting Regime. This marks the first meaningful indication of the FCA’s direction for the next evolution of MiFID in the UK.

On 4 December 2025, Qomply is hosting Tom Soden from the FCA in a Breakfast Roundtable to unpack some of the proposed changes to the MiFID regime.

Below is a quick glance at some of the key changes. As our team continues to read through the consultation paper, we will update with further commentary.

Descope FX derivatives from MiFID and Leverage UK EMIR

This will come as welcome news in the industry and addresses the duplication concern raised by the industry between MiFID and EMIR. By removing the obligation to report FX derivatives from MIFID, the FCA argues that “This would create significant cost savings for reporting firms by simplifying their processes and forego the need to submit transaction reports in FX derivatives. ”

Reduction of Back-Reporting Obligations: 5 Years → 3 Years

The FCA proposes shortening the default back-reporting window from five years to three.

Most firms already stay on top of their Errors and Omissions, correcting issues as they go. So by the time these rule changes take effect, many firms will have already fixed most of their older reporting problems. That means the immediate cost savings may be small, but over time the industry will welcome cutting the back-reporting window from five years to three, especially since the FCA wasn’t really using the full five years of data anyway.

This may have implications for ARMs whose pricing models rely heavily on charging premiums for back-report submissions.

Removing Instruments Tradeable Only on EU Trading Venues

The FCA proposes removing the obligation to report instruments only tradeable on EU venues, which would: “Remove reporting obligations for over 6 million instruments only tradeable on EU trading venues.”

This may help bring down costs of reporting for some firms.

Allow Firms to Over-Report Index Derivatives

Working out whether an index derivative needs to be reported often takes more time and effort than just reporting it. To fix this, the FCA is proposing to let firms simply over-report any derivative based on an index. This removes a big headache for many firms and makes the rules much easier to follow.

Easier Reporting for Baskets

The FCA is also making basket reporting simpler. They plan to relax their validation rules so firms can include non-reportable ISINs in the list of basket constituents (Field 47 – Underlying Instrument Code). As long as at least one ISIN in the basket is reportable, the FCA will accept the report. This change reduces unnecessary rejections and simplifies the whole process.

Some Relief of Reporting for Buy-side Firms

For over 18 months, buy-side firms have lobbied for exemption from MiFID reporting, arguing that sell-side firms already provide duplicate data.

The FCA disagrees. It cites that 56% of buy-side trades are not duplicated, and removing buy-side reporting would cause the FCA to lose visibility over more than half of buy-side activity, particularly in gilt and sterling markets.

The Compromise: Conditional Single-Sided Reporting (CSSR)

Conditional Single-Sided Reporting (CSSR) lets one firm report the trade for both sides. Today it is rarely used because it's cumbersome. The FCA wants to simplify the process and allow its use in every trading capacity so that more firms can rely on one-sided reporting and reduce costs without reducing data quality.

This is an example of the FCA loosening requirements to expand when CSSR can be used.

Clarification for Reporting Price for Equity Swaps

The FCA proposes:

• For single-underlying equity swaps: the underlying instrument price must be reported in the price field.

• For multi-underlying swaps: firms should report the price field with the price of the underlying instrument(s) or index where available. Where the underlying price is not available, the spread of the financing rate should be reported.

Further guidance will be published in the upcoming user pack, especially for other derivative types.

“Complex Trades” Replaced with “Package Transactions”

This change aligns MiFID with EMIR terminology and simplifies classification.

Reduction of Fields in MiFID Reports

Transaction Reporting Fields Reduced from 65 to 52.

Instrument Reference Data Fields Reduced from 48 to 37

FCA Continues to Support Direct Reporting

The FCA confirms it will continue to support firms submitting directly to the MDP. However, onboarding fees remain high and continue to be a barrier for smaller firms.

ISINs Remain – UPIs Deferred

Despite industry lobbying, the FCA has decided not to adopt UPIs at this stage. The FCA argues that UPIs lack granularity and would increase, not reduce, reporting requirements.

Block vs Fill Reporting – No Change (Yet)

For those firms hoping that they could report on Block level instead of the costly Fill level, unfortunately, the FCA reviewed and changes would be difficult to implement. The FCA plans to revisit this topic and may propose guidelines on block/fill reporting in next year’s transaction reporting user pack consultation.

INTC (Aggregate Client Linking Code) – Deferred

There was quite a lot of buzz around simplifying INTC reporting convention. Looks as though these changes will have to wait.

Additional Clarifications and Guidance

The FCA commits to providing clearer guidance and examples through a new Transaction Reporting User Pack, addressing problematic fields and common reporting challenges.

Next Steps

While this summary highlights several major themes, the Consultation Paper contains numerous additional proposals—many of which will ease reporting burdens for Trading Venues and Systematic Internalisers.

Qomply will continue analysing the Consultation Paper and will release detailed insights across all impacted areas.

In the meantime, if you’d like to put your questions directly to the FCA about these proposals, we invite you to join us at the Qomply Breakfast Roundtable on 4 December 2025.