August 2026
The regulatory reporting landscape is entering a new phase of simplification. Both the UK FCA and ESMA have recently introduced significant initiatives aimed at reducing complexity, streamlining data requirements and improving the effectiveness of transaction reporting regimes. This article examines the changes and the impacts on firms.
At a glance
- UK reforms to MiFIR transaction reporting will need to be implemented by 3 April 2028: new requirements will reduce transaction-reporting fields from 65 to 52, remove FX derivatives and EU-only instruments from scope, and shorten the default back-reporting period from five to three years.
- ESMA’s proposed reforms impact MiFIR, EMIR and SFTR reporting but the timetable is less clear: ESMA’s longer-term “report once” model aims to replace fragmented MiFIR, EMIR and SFTR processes with a single modular framework, while providing interim burden-reduction measures.
- Firms should take a strategic approach: use the reforms to remediate legacy issues, identify duplication across regimes and build a more reusable reporting architecture, while managing near-term divergence between UK and EU requirements.
A new direction for transaction reporting
Over the past decade, transaction reporting requirements have expanded significantly across wholesale financial markets. MiFIR, EMIR and SFTR introduced extensive reporting obligations to provide regulators with greater transparency into market risk, trading activity and systemic exposures. However, the resulting framework has often created overlapping requirements, duplicated reporting and substantial operational complexity.
In the EU and the UK there are now initiatives to simplify the reporting. Although the overall objectives of the reforms are the same, the implementation is slightly different. The UK is progressing with a targeted reform of the MiFIR transaction reporting framework and has given responsibility for the longer-term reform of MiFIR, EMIR and SFTR to a taskforce. ESMA has set out in more detail its longer-term ambition to create a ‘report once’ integrated cross-regime reporting model spanning MiFIR, EMIR and SFTR but has proposed some nearer-term reforms to all the regimes.
For firms already managing multiple regulatory reporting programmes, these developments represent both an opportunity and a challenge. The changes have the potential to reduce duplication, lower compliance costs and improve data quality, but they will also require strategic planning, technology investment and careful implementation management.
Key UK MiFIR regulatory changes
The FCA’s Policy Statement PS26/15 implements the UK Government’s intention to replace the existing MiFIR transaction reporting framework with a more proportionate and streamlined regime embedded within the FCA Handbook. The reforms introduce significant adjustments across entity scope, product scope, reporting activities and data fields.
A new definition of a “transaction reporting firm” will apply to MiFID investment firms and certain third-country firms conducting MiFID or equivalent business from a UK establishment. For now, collective portfolio management investment (CPMI) firms remain outside the scope of MiFID transaction reporting requirements however the regulator is considering applying reporting obligations for these firms as part of its review of fund reporting for asset management entities. The FCA is also removing the obligation for Systematic Internalisers to report instrument reference data.
Several product-related simplifications are being introduced. FX derivatives will be removed from MiFIR transaction reporting because equivalent information is already reported under UK EMIR. The FCA is also removing reporting obligations for financial instruments that are only tradeable on EU trading venues. However, the ISIN will remain the primary product identifier and instruments traded on UK trading venues will continue to be reportable.
The reforms include modifications to the transaction transmission mechanism intended to reduce reporting burdens, particularly for smaller UK investment firms. In addition, the default historical back-reporting period will be reduced from five years to three years.
One of the most significant changes is the reduction in mandatory reporting fields from 65 to 52. Several indicator fields, including waiver, OTC post-trade, short selling, commodity derivative and SFT indicators, will be removed entirely. For many firms, these field-level changes will drive technology enhancements, data model updates and changes to reporting controls.
Firms will need to comply with these changes by 3 April 2028. As the changes are often removing requirements, the FCA is going to take a flexible supervisory approach allowing firms that are ready to make certain changes before 3 April 2028. The FCA lists the allowable changes in the policy statement.
The FCA, with the Bank of England, has also established the Transaction and Post-trade Reporting Industry Harmonisation Taskforce which will take a longer-term approach to harmonising the reporting under MiFIR, EMIR and SFTR.
ESMA’s “report once” vision
While the FCA’s reforms deliver near-term simplification, ESMA has focused more on a broader strategic objective: the creation of an integrated reporting ecosystem. ESMA identifies fragmentation across MiFIR, EMIR and SFTR as a key driver of compliance costs, operational effort and reporting complexity. To address this, the regulator has proposed two complementary workstreams.
The first package focuses on practical improvements that can be implemented more quickly. These intermediate measures include broader use of delegated reporting, streamlining EMIR intragroup reporting exemptions, reducing historical correction reporting horizons from five years to three years, expanding transaction reporting exemptions for certain fund operations, low-risk corporate actions and employee share plans, de-prioritising selected optional MiFIR reporting fields, simplifying EMIR reconciliation and errors-and-omissions frameworks, and excluding certain SFTR transactions where settlement fails before the reporting deadline.
The longer-term proposed ‘report once’ framework would create a single integrated reporting model, harmonised reporting templates, consistent data definitions and streamlined reporting infrastructure across multiple regulatory regimes. Under this vision, firms would move towards a single source of regulatory reporting data, reducing duplication and enabling greater consistency across reporting obligations. ESMA estimates that such an approach could generate substantial long-term benefits while improving supervisory effectiveness.
ESMA’s proposed roadmap indicates a phased implementation stretching into the next decade, with a fully integrated framework not anticipated until 2031. The intermediate measures will be implemented sooner. However, some of the intermediate measures require legislative changes so the timetable is not yet clear.
Implications for firms
Although simplification is the primary objective of both initiatives, regulated firms should not underestimate the scale of change required. Simplification will still require material change: updates to source systems, data models, data mapping, reporting engines, reconciliations, governance and testing are likely despite the overall reduction in reporting obligations.
Firms can start preparing now for the revised UK regime taking effect on 3 April 2028 by assessing scope, reporting logic, data fields, schemas, validation rules and related controls.
Data quality remains critical - firms should not interpret fewer fields as lower supervisory expectations and should continue to prioritise complete, accurate and consistent reporting.
Most firms already face extensive regulatory transformation agendas as well as managing historical reporting issues and remediation programmes. The FCA reforms must now be incorporated into existing reporting programmes, alongside ongoing work linked to EMIR, SFTR and global reporting requirements. Both the FCA and ESMA reforms create an opportunity to address legacy problems before new requirements become effective. Firms will need to assess competing priorities, implementation timelines and resource constraints - consolidating remediation activity alongside regulatory change delivery may help reduce overall implementation effort and future compliance risk
Many of the proposed reforms require firms to reassess underlying reporting architectures. ESMA’s “report once” vision raises important strategic questions about whether current reporting infrastructures can support a future integrated reporting model. Firms that begin assessing overlapping obligations across MiFIR, EMIR and SFTR today may be better positioned to benefit from future regulatory harmonisation and avoid repeated investments in fragmented reporting solutions.
How KPMG in the UK can help
KPMG can help firms evaluate existing reporting governance frameworks to understand the impact of the regulatory changes on the operating model. Through a regulatory impact assessment, organisations can identify key gaps and areas requiring substantial enhancement to support future compliance.
For firms managing legacy reporting issues, KPMG can provide root cause analysis, back-reporting support, remediation programme delivery and data testing services. Integrating remediation activity with wider regulatory change programmes can help improve efficiency and reduce implementation risk.
KPMG’s experience supporting financial institutions through major reporting transformations enables us to provide practical insights into regulatory developments, market practice and implementation approaches across multiple jurisdictions and reporting regimes.
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