What FCA PS26/15 changes and what it quietly shifts onto your team
On 3 April 2028, UK transaction reporting fields will drop from 65 to 52, the default back-reporting window will shrink from five years to three, and FX derivatives will leave the regime entirely. For compliance teams that spend a great deal of time on this filing, this should be a huge relief.
Unfortunately, it isn’t quite that simple. FCA PS26/15, “Improving the UK Transaction Reporting Regime,” published in August 2026, is a genuine exercise in simplification. The FCA expects it to save UK firms more than £100M annually, compared with the £493M currently spent on UK MiFIR transaction reporting alone. But nearly every line item that gets shortened also moves a decision, data dependency, or liability question onto your team rather than removing it.
What the FCA Is Actually Changing
Fewer fields. The field count drops from 65 to 52, and the regimes geographic reach narrows to instruments tradeable only on UK trading venues, removing roughly seven million instruments that are tradeable only on EU venues.
FX derivatives are out. Options, futures, swaps, and forward rate agreements on currencies no longer need to be reported under UK MiFIR. UK EMIR becomes the primary source for this data instead, cutting costs for more than 400 UK firms.
Back reporting shrinks, with a catch. The default correction window falls from five years to three. The FCA retains the power to demand up to five years on an exceptional basis for serious reporting failings, and the underlying five-year recordkeeping obligations under COBS 11 and SYSC 9 don’t change at all.
Single-sided reporting model. Conditional Single-Sided Reporting (CSSR) cuts the data points a firm must provide from 10 to four. It extends to firms in DEAL and MTCH trading capacities and is entirely optional.
Wider exemptions for corporate actions. Nearly all corporate event activity is now excluded from reporting, apart from IPOs, secondary offerings, placings, and debt issuance.
Why Shorter Doesn’t Mean Simpler
Each of these changes removes a filing obligation, but adds a judgment call somewhere else in the process.
Narrowing the scope makes FCA FIRDS a harder-working golden source. As EU-only instruments drop out, firms that rely on FIRDS to determine reportability need that reference data to reflect the new perimeter correctly. But the FCA has said it’s still deciding when to stop ingesting EU instrument data ahead of 2028. If you get that timing wrong, you may over-report instruments that no longer matter or under-report those that still do.
CSSR is optional for a reason. Most respondents to the FCA’s consultation said the sending-and-receiving split works better in theory than in practice, particularly around who’s liable when the sending firm’s data turns out to be wrong. Any firm that opts in as a receiving party without first settling that liability question contractually will inherit a remediation problem it didn’t create.
In fact, the back-reporting reduction isn’t the advantage it seems to be. These aren’t new obligations. What’s changed is the exceptional-basis power the FCA keeps in reserve. Firms still have to hold five years of underlying transactions and order records regardless of the reporting window. As a result, fewer routine corrections do not necessarily mean a shorter audit trail.
The Calendar Compliance Teams Need
Supervisory flexibility on several fronts, including FX derivatives and EU-only instruments, started on 3 August 2026. The FCA will publish draft schema, validation rules, and a new Transaction Reporting User Pack in October 2026. This is where you can find worked examples on trusts, fractional instruments, and branch execution. The full regime takes effect on 3 April 2028, once HM Treasury repeals the current UK MiFIR transaction reporting legislation. The new schema are also backwards compatible, so firms can resubmit historical reports under it once the rules are live.
How the IVP Regulatory Reporting Solution Helps
A shorter field list and a narrower instrument scope don’t change what regulators will ask when a figure gets questioned: where did this number come from, and which rule set was in force on the trade date? The IVP Regulatory Reporting Solution is built for firms managing overlapping regimes all at once rather than in isolated filings. It also addresses the specific pressure points this overhaul creates:
- Coverage built for overlap, not isolation. The solution automates more than 30 global regulatory filings across seven core datasets, including Form PF and AIFMD, so a scope change in one regime doesn’t mean you have to build a separate reporting process.
- Two rule sets, clearly tracked. Because the FCA’s new schema are backwards compatible, firms will be running old and new validation rules in parallel for as long as legacy reports need to be resubmitted. The IVP Regulatory Reporting Solution tracks each filing’s status from draft to submission and timestamps what changed along the way, so a firm can show exactly which rules applied to which reports without reconstructing an audit trail after the fact.
- Lineage that survives a field-count change. A golden record of underlying position and trade data maintains the derivation behind any figure, whether it is filed under the old 65-field regime or the new 52-field one. Data lineage is fully documented, eliminating the need for a week-long impromptu research project if an examiner asks for it.
- Clearer CSSR decisions. Opting in as a receiving firm means taking on exposure to another party’s data quality. That’s a call each firm has to make on its own terms, but it’s easier if the data feeding both sets of obligations already sits on a single, validated, traceable platform instead of disconnected systems.
- Optional resourcing for the 18-month window. For firms weighing how to staff implementation against everything else on the compliance calendar, our “regulatory reporting as a service” model offers a managed alternative to building it in-house.
Learn more about the IVP Regulatory Reporting Solution.
