Why does the article say firms remain sceptical of the FCA's 25% UK MiFID cost-savings estimate?

It says firms remain sceptical because the transition will require significant upfront investment before any end-state savings are realised. The poll cited in the article shows that 58% of respondents thought it was too early to tell or were unsure.

What did Qomply's poll identify as the biggest implementation challenge in the UK MiFID rewrite?

It identified familiarisation with the new requirements as the biggest challenge. The article says 52% of respondents ranked interpretation of the new guidelines above technology as the primary obstacle.

What hidden implementation costs does the article highlight in the FCA's UK MiFID rewrite?

It highlights IT upgrades and data-lineage work as the biggest expected costs. The article says 74% of respondents identified IT costs and upgrades as their main implementation burden.

Why does the article treat Conditional Single-Sided Reporting and additional data fields as part of the challenge?

It treats them as part of the challenge because they increase interpretive and system-change complexity. The article says many of the proposed fields will require regulatory analysis and IT changes before implementation can begin.

What should firms do now if they want to reduce transition risk under the proposed UK MiFID rewrite?

They should start building early visibility into data gaps, rule changes, and required process enhancements before the final switchover. The article says early preparation and structured understanding of likely changes will help firms transition more smoothly once the FCA finalises the regime.

Insights

The UK MiFID Rewrite: FCA Predicts Savings. Industry Remains Skeptical

Published: 23rd February 2026

The FCA expects cost savings from the UK MiFID rewrite, but many firms remain skeptical about the scale and timing of those efficiencies.
Implementation complexity is being underestimated, particularly around data sourcing, mapping logic and systems changes.
Knowledge gaps pose a material risk, with many firms unsure how the new framework will affect their reporting controls.
Governance and quality assurance will be critical to avoid post-implementation remediation and regulatory scrutiny.
Early preparation reduces risk, especially where trade capture, reconciliation and backreporting processes may require redesign.

The FCA's proposed UK MiFID rewrite promises material cost savings and a streamlined reporting framework. However, industry sentiment suggests a more cautious outlook. Drawing on market feedback and regulatory analysis, this article explores the differences between projected efficiencies and practical implementation challenges.

The Financial Conduct Authority's (FCA) Consultation Paper (CP25/32) proposes the most significant overhaul of the UK transaction reporting regime since its introduction in 2018.

By its own account, the FCA is predicting that these changes will ultimately save the industry around one-quarter (25%) of firms' current annual transaction reporting costs.

However, a recent industry poll conducted by Qomply suggests the market is hesitant to bank on these savings just yet.

Qomply polled over 250 industry practitioners, across the buyside and sellside, and the data reveals a stark gap between regulatory intent and operational reality.

The Verdict: Too Early to Tell

Despite the FCA's estimate, the industry is cautious. When asked if they anticipated savings around 25%,

58% of respondents stated it was too early to tell or were unsure.
Only 3% believed savings would be higher than 25%.
22% actually predicted savings would be lower than the regulator's estimate.

This scepticism likely stems from the cost of change. While the end state, reporting on fewer instruments, is leaner, the transition requires significant upfront investments to untangle legacy systems.

Question: The FCA estimates that the proposed measures in CP25/32 could deliver cost savings equivalent to around one-quarter of firms' current annual transaction reporting costs. Do you think the actual savings for your organisation will be:

UK MiFID Rewrite: Survey Results 1

The Knowledge Gap Is the Primary Challenge

The poll identified that the single biggest hurdle for implementation is not technology, but interpretation of the potential guidelines.

52% of respondents cited Familiarisation with the new requirements as their biggest challenge.
This was followed by data lineage/New schemas (32%) and Development of new processes (32%).

This signals a need for subject matter expertise. CP25/32 introduces significant complexity, including the new Conditional Single-Sided Reporting Model and a battery of additional data fields. Many of these fields may require changes to IT systems, and their interpretation requires regulatory analysis before implementation can begin.

Question: What is the biggest challenge you expect to face in implementing the new regime (Multiple choice)

UK MiFID Rewrite: Survey Results 2

IT and Data Lineage: the Hidden Costs

Once the rules are understood, the focus shifts to execution. A massive 74% of respondents identified IT costs/upgrades as their biggest expected implemented cost.

This aligns with the need for what Qomply calls Operational Intelligence. Firms are realising that adapting to the UK MiFID rewrite will require more than just updating fields.

Question: What do you feel the biggest implementation costs will be (Multiple choice)

UK MiFID Rewrite: Survey Results 3

The Bottom Line

The UK MiFID rewrite offers a potential path to savings on transaction reporting, but the path remains unclear and complex. As the poll results indicate, the majority of firms are waiting for more clarity before they accept the regulator's savings projection as fact.

The final revisions to MiFID are expected later this year. Once the FCA formalises the requirements, Qomply will work closely with clients to support a smooth transition. In addition to providing a dedicated UAT environment, we will proactively highlight the data fields that are expected to change as well as new rules that will highlight upcoming changes that may be required in their reporting.

This approach is designed to give firms early visibility of potential gaps within their current MiFID reporting and a clear understanding of the enhancements that may be required ahead of the switchover. By sharing insight as the framework develops, we aim to help clients prepare in a structured and informed way.

Qomply’s MiFID Transaction Reporting solutions will incorporate flags and warnings to highlight potential gaps arising from the new requirements, once finalised. In addition, we will be offering a standalone Quality Assurance environment to enable testing well in advance of go-live to support gap analysis and provide a practical testing framework ahead of implementation.

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It says firms remain sceptical because the transition will require significant upfront investment before any end-state savings are realised. The poll cited in the article shows that 58% of respondents thought it was too early to tell or were unsure.
It identified familiarisation with the new requirements as the biggest challenge. The article says 52% of respondents ranked interpretation of the new guidelines above technology as the primary obstacle.
It highlights IT upgrades and data-lineage work as the biggest expected costs. The article says 74% of respondents identified IT costs and upgrades as their main implementation burden.
It treats them as part of the challenge because they increase interpretive and system-change complexity. The article says many of the proposed fields will require regulatory analysis and IT changes before implementation can begin.
They should start building early visibility into data gaps, rule changes, and required process enhancements before the final switchover. The article says early preparation and structured understanding of likely changes will help firms transition more smoothly once the FCA finalises the regime.