FCA sets reporting roadmap ahead of 2028 regime

The Financial Conduct Authority is consulting on guidance, transitional provisions and related Handbook changes for a new transaction reporting regime, with rules due to come into force on 3 April 2028.

CP26/34 sets out implementation material rather than an earlier effective date for the new framework. The FCA says its proposals are intended to support consistent reporting during and after implementation, helping it monitor financial markets, conduct market abuse surveillance and carry out supervisory work.

Guidance becomes a data and transition exercise

CP26/34 proposes guidance on changes made in the new rules, provisions to clarify the transition to the future regime and amendments to the Handbook and Technical Standards referring to MAR 13, MAR 14 and MAR 15.

The FCA also proposes carrying relevant parts of existing guidance from the Handbook's 'Level 3 Materials' section into a new Transaction Reporting User Pack. It asks whether the proposed guidance gives firms enough clarity on the new regime and where further guidance or examples are needed.

The consultation itself does not bring the new reporting framework into force. The FCA says the new rules will come into force on 3 April 2028, while the material under consultation is intended to support the move from existing arrangements and reporting under the future regime.

That sequence gives firms a defined planning mechanism: map current reporting roles and data flows against the draft schema, validation rules, proposed guidance and transition provisions. The exercise is an operational response to the FCA's materials, not an additional requirement created by CP26/34.

The affected cohort is defined by data submission

The FCA identifies investment firms, operators of trading venues and approved reporting mechanisms as consultation audiences. It also names trade associations and other market participants involved in submitting transaction reports, instrument reference data or order book data.

The source does not allocate a separate planning burden to each category. It does, however, identify the reporting functions that should frame the review: each participant should establish whether its role involves transaction reports, instrument reference data, order book data or a combination of those streams.

The FCA has published a draft schema and validation rules through its Market Data Processor webpage to support preparation for 3 April 2028. Those materials provide an early basis for comparing existing submissions with the proposed future format, while leaving room for changes following consultation and later FCA publications.

This is where the supervisory signal becomes concrete. The FCA links transaction reports to its monitoring of financial markets, market abuse surveillance and supervisory activities. A reporting process that cannot explain how its data maps to the proposed schema would therefore leave an evidence gap in the mechanism the FCA is preparing to use for oversight.

The consultation does not prescribe a new internal control framework. A possible response is to record the relevant reporting role, identify affected data fields and test validation outcomes against existing submission processes, with any gaps converted into specific consultation questions or requests for examples.

The next test is the User Pack

Responses to CP26/34 are due by 6 November 2026. The FCA accepts comments through its online response form, by email or in writing to its Transaction & Position Reporting Team.

The FCA plans to consult on a new Transaction Reporting User Pack in Q1 2027 and publish the final version by 3 April 2027. That pack is intended to carry relevant existing guidance and will provide the next formal opportunity to assess whether the implementation material answers the questions firms raise during the current consultation.

The timetable leaves two separate milestones. Firms must submit requests for clarity, examples and transition guidance by 6 November 2026, then compare the Q1 2027 User Pack consultation and the final pack against those issues.

The next observable supervisory test is whether the Q1 2027 User Pack consultation, followed by the final pack due on 3 April 2027, addresses the clarity and examples firms request by 6 November 2026.