FCA consults on practical steps for implementing new transaction reporting regime (CP26/34)

# What happened On 2 October 2026 the Financial Conduct Authority published Consultation Paper CP26/34, titled "Preparing for the new transaction reporting regime." The paper follows PS26/15, which set the new transaction reporting rules and confirmed an implementation date of 3 April 2028. CP26/34 is an implementation-focused consultation designed to explain how firms should apply the new framework in practice rather than to introduce further substantive policy change.

# Why the FCA is consulting HM Treasury intends to repeal the existing UK MiFIR transaction reporting legislation so the FCA can replace it with a Handbook-based framework. Transaction reports under the retained UK MiFIR rules are a primary data source for the FCA's market monitoring, market abuse surveillance and supervision. CP26/34 aims to give firms greater certainty about operational, reporting and transitional arrangements ahead of the April 2028 switch.

# What CP26/34 proposes The consultation contains a package of practical measures and materials intended to help firms prepare for the new regime:

• Transaction Reporting User Pack: The FCA proposes a consolidated user pack that brings guidance, clarifications and reporting examples together in one resource. This will replace current Level 3 materials in the Handbook and is intended to make guidance easier to find and apply.

• Seven initial guidance topics: The FCA is consulting on guidance in seven areas where firms need clarity before implementation. These are:

• package transaction reporting, including package identifiers, pricing and reporting of individual legs.

• April 2028. These address treatment of reports and instrument reference data submitted around the implementation date, handling of transactions executed shortly before implementation but reported after it, corrections, reconciliations and record-keeping post-implementation.

• Draft schema and validation rules: Alongside CP26/34 the FCA has published draft transaction reporting schema and validation rules to help firms prepare technically for the new regime.

# Timing and next steps Responses to CP26/34 are requested by 6 November 2026. The FCA expects to publish a further consultation on the Transaction Reporting User Pack in Q1 2027 and to publish the final user pack by 3 April 2027 to give firms a year for implementation before the 3 April 2028 effective date.

# Practical takeaway for firms Firms should review the seven guidance areas against their reporting processes, test the draft schema and validation rules, and plan reconciliation and record-keeping activities for the migration window. They should also monitor the planned User Pack and the later consequential Handbook amendments so operational and governance arrangements match the Handbook-based regime.