FCA’s MiFIR Overhaul: Key Changes and Their Impact on UK Investment Firms

Welcome to 2026. If you like reading Final Reports and planning regulation changes, this year is for you. Last year ESMA surprised many when they dropped a ‘Call for Evidence’ paper to gather feedback on views to reduce burdens for transaction reporting. The paper introduced various options to change scope and format of MiFIR, EMIR and SFTR reporting with ESMA feedback slated to arrive sometime in Q1 and potentially this month.

While we await results from ESMA’s Call for Evidence and potential changes and timelines, the FCA launched their own version of changes to MIFIR that are expected to go live at the end of 2027 or 2028. The FCA’s proposals where raised in their Consultation Paper on Improving UK Transaction Reporting that aims to reduce burdens of the daily reporting requirements and lowering costs for investment firms complying with the regulation. The consultation paper currently is open until February 20^th, 2026 for feedback and the current proposals took into account feedback from the FCA’s late 2024 discussion paper on the subject.

According to the FCA, the more efficient format of reporting will lead to cost savings of £942.8 million over 10 years after adjusting for expenses related to firms to adjust to the new standards. Much of the saving comes from reduction of products under scope which will decrease yearly submitted messages.

Firms have until February 20^th, 2026 to respond. Below are a number of the key takeaways from the proposal.

Field changes

In their analysis, the FCA identified a number of fields that can be removed due to no longer being relevant or providing limited benefits for their supervisory monitoring. There are also fields being adjusted and added to better align with EMIR and SFTR data and to improve information available to monitor for market abuse.

Removed fields

The FCA listed a number of fields for removal as the data no longer applies post Brexit, information can be inferred from the CFI code or not used for monitoring purposes.

• Transmission of Order Indicator (Field 25)
• Derivative notional increase/decrease (Field 32)
• Country of branch membership (Field 37)
• Notional Currency 2 (Field 45)
• Option Type (Field 50)
• Option exercise style (Field 53)
• Maturity Date (Field 54)
• Delivery type (Field 56)
• Country of supervising branch (Fields 58 and 60)
• Indicator fields (Fields 61-65)

Changed/added fields

• Fields 8 & 17 – ‘Country of Branch of Buyer/Seller’ fields are changed to ‘Client Indicator of Buyer/Seller’. Due to the FCA observing confusion for when the Country of Branch fields should be filled out, they have adopted a more standard TRUE/FALSE format for indicating when a counterparty on a report is a reporting firm’s client.
• Field 59 adding DEA Indicator value to the Execution Within Firm field – Here the field remains the same but new value of DEAU added to be entered if the investment firm provided direct electronic access to a venue for their client.
• Field 40 Complex Trade field amended – Being changed to align with EMIR and renamed ‘Package Identifier’ and adding two new fields of ‘Package Price’ and ‘Package Price Currency’.

Back Reporting

In the Discussion Paper, the FCA received feedback on methods to reduce burdens for Back Reporting. Among them was addition of an ‘Amend’ action type for correcting historical submissions. This would reduce the current requirements of reporting a Cancelation (CANC) and Replay (REPL) of the submission which can double line costs associated with back reporting. The FCA decided against adding an Amend function, but to reduce potential work and costs of reporting corrections and underreported trades have reduced to back reporting requirements from 5 to 3 years.

Scope Changes

UK FIRDS Alignment

The cornerstone of MIFIR scope are products that trade on a trading venue (TOTV) and for derivatives their underlying trades on a trading venue (UTOTV). Following Brexit, the FCA continued to include products within FIRDS scope that were TOTV/UTOTV of EU venues even as ESMA removed UK traded products from their version of FIRDS. As part of the Consultation Paper, EU TOTV/UTOTV products are proposed for removal from UK FIRDS.

FX out of scope

One proposal that should help many firms to reduce their reported volumes and reduce confusion of ‘what is reportable’ is the removal of FX derivatives from being under scope for MIFIR transaction reporting. According to the FCA, available data on FX derivatives from EMIR reporting reduces the need of similar information derived from MIFIR submissions for monitoring against market abuse. For reporting firms, the proposal also removes confusion of handling bilateral OTC FX transactions of which there is the question of scope and if reportable what ISIN to use.

Equity Index Flexibility

In various Market Watch reports published by the FCA, they’ve made mention of firms needing to monitor for overreporting. Often overreporting is the result of ambiguity of scope of a product and companies taking the ‘its better to report than not report’ attitude. The FCA added a proposal that will now allow overreporting of Equity Index Derivatives even if none of the index constituents are in scope of MIFIR. This is due to the FCA’s acknowledgment that determining scope of Index’s can be challenging as a product is in scope if even on constituent of an Equity Index has an ISIN included in UK FIRDS.

Delegated reporting

While popular for EMIR among buy-side companies, delegated reporting where one firms reports on behalf of themselves and their counterparty is limited under MIFIR. Operationally it is harder under MIFIR as reports require personal identification identifiers (PII) of traders and portfolio managers that investment managers aren’t able to or prefer not to provide to their counterparties to report on their behalf. To allow for more scenarios where delegated reporting can be applied, the FCA is proposing to reduce the number of fields needed for the report to make it more accessible for buy-side firms to leverage their counterparts reporting for them.

Timelines

As mentioned above, the Consultation Paper is open for feedback until February 20^th, 2026. According to the FCA they plan to then make a Policy Statement of changes to MIFIR reporting later in the year in H2 2026 with a go-live date of 18 months after the Policy Statement. While not expected, the FCA could elect to use a shorter timeframe for implementing the go-live.

Have questions?
Contact Cappitech’s regulatory experts today here to discuss how these changes impact your reporting and how we can help you stay compliant.

About the author: Ron Finberg

Ron is Executive Director, Product Specialist at S&P Global Market Intelligence Cappitech and helps customers with their compliance of EMIR, MIFIR, SFTR, MAS and ASIC derivative reporting. Ron is an ongoing contributor of regulatory focused content and webinars and leverages his over 20 years’ experience in the financial industry. He was also awarded the Editor’s Recognition Award for Best RegTech Vendor Professional in the RegTech Insight Europe Awards 2021.