FCA CP25/32: Proposed Changes to UK MiFID Transaction Reporting

Key Proposed Changes to Improve MiFID

The FCA's CP25/32 consultation proposes significant reforms to UK MiFID transaction reporting, including scope changes (such as FX derivatives), a shorter back-reporting window, and simplifications for index derivatives and basket reporting. This article summarises the key proposals and highlights practical operational implications for reporting teams as the FCA moves toward an updated UK reporting framework.

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 hosted 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: From 5 Years to 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.

Data Fields at a Glance

Fields Removed

• Field 25 Transmission of Order Indicator
• Swap In/Out tags
• Field 32 Derivative Notional Increase/Decrease
• Field 37 Country of Branch Membership
• Field 45 Notional Currency 2
• Field 50 Option Type
• Field 53 Option Exercise Style
• Field 56 Delivery Type
• Field 54 Maturity Date Field 58 - Country of the branch responsible for the person making the investment decision
• Field 60 Country of the branch supervising the person responsible for the execution
• Field 61 Waiver Indicator
• Field 62 Short Selling Indicator
• Field 63 OTC Post-Trade Indicator
• Field 64 Commodity Derivative Indicator
• Field 65 SFT Indicator

Fields Added

• Package Transaction (used with Package Identifier)
• Price Currency

Fields Amended

• Field 8 & 17 replaced with TRUE/FALSE Client indicator fields
• Field 40 Complex Trade becomes Package Identifier
• Field 5 updated to Executing entity is a transaction reporting firm
• NOAP accepted as Strike Price 
• DEA accepted as a value for Field 59 (Execution within Firm)