Supervisory Flexibility Explained: What Firms Can Change Now, What Must Wait and How to Plan for 3 April 2028
The FCA’s PS26/15 reforms are reshaping the UK MiFIR transaction reporting regime, with the new rules taking effect on 3 April 2028. But firms do not have to wait until then to act. During the implementation period, the FCA’s supervisory flexibility allows firms to benefit early from selected reforms, subject to specific conditions.
This practical guide helps firms understand what they can change now, what depends on validation and technical updates, and what must wait until 2028. It also includes a practical implementation timeline, governance considerations and a decision checklist to help reporting teams assess each change before acting.
Download the guide to understand where flexibility applies and how to prepare for the transition with confidence.
How Qomply Can Help
Qomply helps financial firms achieve accurate, compliant transaction reporting across global regulatory regimes, while streamlining the operational and audit demands of regulatory reporting.
Our proprietary technology combines AI, automation and advanced data analytics to deliver scalable, audit-ready reporting intelligence. Through forensic-level quality assurance and streamlined reconciliation, Qomply helps firms strengthen data quality and reporting accuracy, automate controls, simplify audit processes and lower overall reporting costs.
Our technology provides greater oversight and operational efficiency while reducing the demands on internal teams.
For firms seeking to outsource their regulatory reporting operations, Qomply also offers a fully managed service. Combining our technology with deep regulatory expertise, Qomply Managed Services operates as an extension of, or alternative to, an in-house reporting function. This flexible model enables firms to outsource reporting operations while retaining the option to bring activities in-house as their own capabilities and resources evolve.
MiFIR | EMIR | SFTR | CFTC | CSA | MAS | ASIC | HKMA
Frequently asked questions
It is a time-limited supervisory approach allowing firms to benefit early from selected transaction reporting reforms before the new regime takes effect on 3 April 2028. It is not a general waiver of MiFIR reporting requirement
From 3 August 2026, firms can use selected flexibilities, including the three-year default back-reporting period, removal of certain EU-only instruments from scope and conditional relief for FX derivatives subject to UK EMIR reporting.
No. Some changes depend on FCA validation updates or technical changes by an ARM, vendor or direct-reporting solution. Firms should confirm technical readiness before changing their reporting.
The new regime takes effect on 3 April 2028. Firms should use the implementation period to prepare their reporting logic, data, systems, controls and testing.
Firms should confirm the change is covered by PS26/15 Chapter 6, check any conditions and technical dependencies, assess downstream impacts and document the decision and supporting evidence.
