PS26/15 Is Here: What Firms Should Really Take Away From the FCA’s Final MiFIR Transaction Reporting Reforms

When the FCA published CP25/32 last year, most of the discussion centred on the headline numbers: fewer reportable fields, fewer reportable instruments and a reduced reporting burden.

PS26/15 confirms that direction of travel, but after working through the final Policy Statement, I don't think that's the most important takeaway.

The real significance of these reforms is that they change how firms determine what should be reported, where data comes from, and how reporting systems need to operate. For many firms, that will require considerably more work than simply updating a field mapping document.

Evolution rather than revolution

Anyone expecting the FCA to reverse course following consultation will be disappointed. The vast majority of proposals have been implemented broadly as consulted.

That shouldn't come as a surprise. The consultation responses generally supported the FCA's objective of simplifying the regime. The debate was never really about whether change was needed; it was about how those changes could be implemented without creating unnecessary operational risk.

In several areas, the FCA has clearly listened.

The final rules refine a number of proposals around corporate actions, trust identifiers, basket reporting and unknown counterparties. None of these fundamentally changes the policy direction, but collectively they make the framework more practical to implement.

That matters because transaction reporting is ultimately an operational process. Small changes to reporting logic can have a disproportionate impact on technology builds, testing programmes and day-to-day controls.

Fewer fields does not mean less work

One of the headlines from PS26/15 is the reduction in reportable fields.

On paper, that sounds like simplification.

In practice, the implementation effort is likely to be driven by the fields that remain rather than those that disappear.

Several of the removed fields are relatively static values that firms already populate through existing reference data or standing data. Removing them is welcome, but it doesn't fundamentally change the reporting process.

By contrast, the changes to reportability, the revised treatment of instruments, new client indicators, package transaction reporting and the move towards a revised XML schema all require firms to revisit existing reporting logic.

In my experience, this is where implementation projects become more complicated than initially expected.

Reportability deserves more attention

If there is one area firms should focus on first, it is reportability.

The changes relating to territorial scope, FX derivatives, post-trade risk reduction services and corporate actions mean many firms will need to revisit assumptions that have existed since MiFID II was introduced.

That review shouldn't wait until technical specifications are finalised.

A well-run impact assessment can identify affected products, business lines and data sources long before development work begins.

The consultation wasn't just a formality

One aspect I found encouraging was the FCA's willingness to adjust several proposals following industry feedback.

The changes to the treatment of unknown counterparties, the refinement of trust identification and the wider exclusion for post-trade risk reduction services demonstrate that the consultation process genuinely influenced the final outcome.

There are also several areas where the FCA has deliberately taken a pragmatic approach during the transition period by applying supervisory flexibility ahead of April 2028.

That gives firms an opportunity to realise some benefits earlier while still planning for the full implementation programme.

Looking beyond PS26/15

Taken in isolation, PS26/15 is a significant piece of domestic regulatory reform.

Viewed alongside ESMA's transaction reporting simplification work and the establishment of the FCA's Transaction Reporting Taskforce, however, it points to something much broader.

Both UK and EU regulators are asking the same question: how can transaction reporting deliver better supervisory outcomes without continually increasing operational burden?

That is a notable shift in emphasis.

For years, transaction reporting reform largely meant adding new requirements. Increasingly, regulators are focusing on improving the usefulness and consistency of the data they receive.

I don't expect this to be the last major change firms see over the coming years.

Where firms should start

Many organisations will understandably wait for the updated schema, validation rules and User Pack before starting implementation.

I think that's a mistake.

There is already enough certainty within PS26/15 to begin a structured impact assessment.

At a minimum, firms should be reviewing:

• product reportability;
• data sourcing;
• reporting logic;
• internal controls;
• reconciliation processes; and
• dependencies on vendors, ARMs and technology providers.

The firms that start this work now are likely to have a far smoother implementation programme than those that treat April 2028 as a distant deadline.

Ultimately, PS26/15 should not be viewed as a simple reduction in reporting requirements. It is an opportunity to simplify reporting frameworks, improve data quality and build more resilient reporting processes. Firms that approach the reforms with that mindset are likely to gain far more than regulatory compliance alone.