Firms subject to FCA transaction reporting rules learned this week that their collective annual compliance bill will fall by £108 million, dropping from £493 million to roughly £385 million once the changes take effect on 3 April 2028. The catch: contracts for difference (CFDs) and spread bets, two products widely used in retail investing, remain fully in scope.
What the FCA Transaction Reporting Rules Actually Change
The Financial Conduct Authority (FCA) has finalised a package of reforms to the UK’s MiFIR transaction-reporting regime, MiFIR being the rulebook that requires investment firms to file detailed records of every trade with the regulator, so it can monitor markets for abuse.
Foreign exchange derivatives leave the regime entirely, relieving more than 400 UK firms of those filing obligations. Reporting requirements also disappear for around 7 million instruments that trade exclusively on EU venues, saving the industry approximately £32 million a year. The number of mandatory data fields per report falls from 65 to 52, and the look-back window for correcting historical errors shrinks from five years to three, a change the FCA expects to cut resubmission volumes by a third.
CFDs and spread bets are a different matter. Because these products are leveraged (meaning traders can gain exposure many times their deposited capital), the FCA concluded they are ‘highly susceptible to market abuse.’ The regulator pointed to June 2025 convictions of two individuals for insider dealing and money laundering; both used CFDs to profit from falling share prices, and the FCA said it identified the activity directly from transaction reports.
That case illustrates why the FCA considers this data non-negotiable. Since MiFID II reporting began on 3 January 2018, the regulator has received over 30 billion transaction reports, with around 6 billion subsequently corrected, according to an FCA freedom-of-information disclosure from May 2022. Therese Chambers, the FCA’s joint executive director of enforcement and market oversight, put the regulator’s position plainly: ‘Transaction reports are the backbone of our market oversight work.’
Firms Face an Upfront Bill Before the Savings Arrive
The FCA estimated one-off transition costs at £148.8 million, the bulk of it IT work at investment firms. Reading the new rules and running a gap analysis alone is costed at £40,000 for a large firm and £2,400 for a small one, across a population of 750 investment firms and 34 trading venues.
Against that, the FCA projects £942.8 million in benefits over a ten-year appraisal period, so the economics favour the change over time, though the upfront spend lands first.
Firms do not have to wait until 2028 to start adapting. A flexible supervisory approach applies from 3 August 2026, meaning those that are ready can align with the new rules from that date.
The FCA has made clear that lighter reporting obligations do not mean lighter enforcement. Infinox Capital was fined £99,200 in January 2025 after failing to submit transaction reports for single-stock CFD trades executed through one of its corporate brokerage accounts between 1 October 2022 and 31 March 2023, the FCA’s first enforcement action under UK MiFIR for transaction-reporting failures. Infinox identified the problem only after a third-party review and did not proactively report it; the FCA found the discrepancy independently.
Enforcement has continued since. Sigma Broking Limited was fined £1,087,300 on 29 July 2025, according to the FCA’s 2025 fines register, for breaches related to MiFIR transaction reporting. Separately, in April the FCA and the Bank of England established a joint taskforce on transaction and post-trade reporting, with working groups on policy, strategy and architecture running for an initial 18 months.
The FCA also acknowledges a surveillance gap its own reforms create. Removing FX derivatives from the regime leaves it with less visibility over 95 UK branches of third-country firms that report under UK MiFIR but not under UK EMIR (the parallel rulebook covering derivatives more broadly).
The EU dimension adds further uncertainty. The FCA’s cost projections assume the European Union simplifies its own reporting regime along comparable lines. The European Securities and Markets Authority (ESMA) launched a call for evidence on this in June 2025, which drew 108 responses before closing on 19 September 2025, according to ESMA’s call for evidence document. An ESMA interim report indicated a final report on preferred simplification options was expected at the start of 2026, though conclusions are not yet settled.
If the EU diverges, firms running a single reporting system across both jurisdictions would need to split their technology and reporting logic into two separate stacks, a cost the current savings estimate does not fully account for. Draft technical schema and validation rules from the FCA are due in October 2026, which will be the next concrete milestone for compliance teams to plan against.
