FCA CP26/34 maps the 2028 transaction-reporting switch

Consultation Paper CP26/34 is the Financial Conduct Authority's implementation map for the UK transaction-reporting regime that takes effect on April 3, 2028, and it is the document firms have to answer before November 6, 2026 if they want the guidance, the correction rules and the FCA Handbook cross-references settled in advance.

The consultation opened on October 2, 2026. Policy Statement PS26/15, published in August 2026, already made the rules. CP26/34 consults on guidance, transitional provisions and Handbook amendments that replace UK Markets in Financial Instruments Regulation (MiFIR) Articles 25 and 26 with MAR 13, MAR 14 and MAR 15. This analysis tests that switch against EU MiFIR Article 26 and the US Consolidated Audit Trail.

Key facts

• Opened October 2, 2026; comments by November 6, 2026, to cp26-34@fca.org.uk or to 12 Endeavour Square (FCA consultation page; CP26/34, Chapter 5).
• Rules in force April 3, 2028, when FCA systems drop UK MiFIR formats (CP26/34, paragraphs 1.3 and 3.1).
• Further User Pack consultation in the first quarter of 2027; final pack by April 3, 2027 (CP26/34, paragraphs 1.8 and 1.10).
• PS26/15 cuts fields from 65 to 52, drops 7 million EU-only instruments, and shortens default back-reporting from five years to three (PS26/15, paragraph 1.8).
• Annual cost of UK MiFIR transaction reporting estimated at £493 million; ongoing savings estimated at £115.3 million a year (PS26/15, paragraph 2.2 and Annex 2, paragraph 1).
• MAR 14.5.1R: complete and accurate report by 23:59:59 UTC on the following working day (PS26/15 made rules, FCA 2026/52).
• Goldman Sachs International, Final Notice March 27, 2019, reference 142888: £34,344,700 under section 206 of the Financial Services and Markets Act 2000 (FSMA) for 220.2 million defective reports (Final Notice).

Methodology and sources for this comparison

This piece uses primary documents read on October 13, 2026. UK sources are the CP26/34 landing page, published October 2, 2026, the CP26/34 PDF and PS26/15, including made rules FCA 2026/52. The EU texts are Article 26 as adopted on May 15, 2014, not the later UK revision, and Article 70 of Directive 2014/65/EU, unamended on legislation.gov.uk since IP completion day. US sources are 17 CFR 242.613, current on the Electronic Code of Federal Regulations (eCFR) as of October 8, 2026, and 15 U.S.C. 78u-2 in the 2023 United States Code. Enforcement is the Goldman Sachs International Final Notice of March 27, 2019. Scope is the United Kingdom, the European Union and the United States. Separate pieces on this regulation desk are context, not sources for the dates.

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What CP26/34 actually asks firms to implement

CP26/34 does not remake the policy. PS26/15 holds the rules, in force on April 3, 2028, after the Treasury repeals the UK MiFIR reporting legislation. This paper moves EU Level 3 material into a User Pack, drafts MAR TP 5, points the Handbook at MAR 13, MAR 14 and MAR 15, and publishes a draft schema, with Market Data Processor (MDP) testing still undated.

The old User Pack lapsed after the Markets in Financial Instruments Directive (MiFID II) in January 2018. Three European Securities and Markets Authority (ESMA) texts would be withdrawn for UK use in April 2028 and still apply until then. Seven topics are open now: fields 8 and 17; optional conditional single-sided reporting (CSSR); MAR 14.3.1G(7) on derivatives; branch execution; equity-swap prices without SwpIn and SwpOut; the NOAP strike flag; and packages, which need not share one price.

CP26/34 is the Financial Conduct Authority consultation, opened on October 2, 2026 and closing on November 6, 2026, on how firms implement transaction-reporting rules the FCA has already made. It proposes guidance in seven areas, a new transitional chapter, MAR TP 5, and consequential amendments so the Handbook cites MAR 13, MAR 14 and MAR 15 instead of UK MiFIR Articles 25 and 26 and RTS 22 and RTS 23. The rules take effect on April 3, 2028, when FCA systems change schema and UK MiFIR formats stop being accepted. A further consultation on the Transaction Reporting User Pack is planned for the first quarter of 2027, with the final pack due by April 3, 2027. Draft schema and validation rules were published with the paper. Annex 2 says there is no cost-benefit analysis in CP26/34 because the guidance adds no obligations. PS26/15 Annex 2 estimates ongoing savings to business of £115.3 million a year, against an annual cost of £493 million stated in paragraph 2.2.

Trades from 00:00:00 UTC on March 31, 2028 through 23:59:59 UTC on April 2, 2028 may use UK MiFIR format if filed before April 3, 2028. Later filings use MAR 14. Old records stay as they are. Corrections from go-live, including older trades, must meet MAR 13, MAR 14 and MAR 15.

Question 13 asks if EU-only instruments should leave the FCA Financial Instrument Reference Data System (FIRDS) before April 3, 2028. That needs a Treasury repeal. Chapter 4 moves the approved reporting mechanism (ARM) definition to MAR 14, drops RTS 22 and RTS 23 labels, and removes the short-selling flag from the Conduct of Business sourcebook (COBS) 11.5A.3R. The FX cut was made in PS26/15 and reported here on August 16, 2026.

How UK, EU and US transaction reporting diverge

Sources: CP26/34; PS26/15; Article 26 as adopted; Directive 2014/65/EU, Article 70; 17 CFR 242.613. Last updated: October 13, 2026.

MAR 14.5.1R runs to 23:59:59 UTC the next working day. Adopted Article 26(1) uses the close of the next working day, then sharing with the lead-market authority and with ESMA on request. Rule 613(c)(3) sets 8:00 a.m. Eastern Time the next trading day and bars an earlier deadline. A Consolidated Audit Trail (CAT) order file is not a MAR 14 report.

The adopted EU article still covers venue instruments and specified underlyings, on or off venue, plus a short-sale flag. PS26/15 has already chosen UK venues, 52 fields and no such flag. The UK statute text, current to October 13, 2026, still says "UK, Gibraltar or EU trading venue". Until repeal, that statute and MAR 14 are not the same source.

UK transaction reporting, EU MiFIR reporting and the US Consolidated Audit Trail are three duties, not three layouts of one form. Article 26(1) of Regulation (EU) No 600/2014, as adopted on May 15, 2014, requires a complete and accurate report to the competent authority no later than the close of the following working day. Article 26(2) covers instruments admitted to trading or traded on a trading venue, and specified underlyings, on-venue or off. Article 26(3) still asks for a short-sale designation the UK is dropping. From April 3, 2028 the UK uses MAR 14.5.1R, a 23:59:59 UTC deadline, and 52 fields rather than 65. The US duty in 17 CFR 242.613(c)(3) is an NMS-security order report by 8:00 a.m. Eastern Time the next trading day, timestamped at least to the millisecond. A firm in all three cannot treat a UK build as proof the EU or CAT file is done.

PS26/15 paragraph 3.1 priced the EU-only cut at about £31.5 million a year, because EU authorities already receive those reports. That is a sharing bet, not a FIRDS feed. The overlap that matters is a UK equity which is also an NMS security: three clocks, and a CAT Customer-ID the UK client indicator does not carry. The same split appears in the UK bond consolidated tape and in MiFID equity transparency moving into the Handbook.

"The failings in this case demonstrate a failure over an extended period to manage and test controls that are vitally important to the integrity of our markets. These were serious and prolonged failures. We expect all firms will take this opportunity to ensure they can fully detail their activity and are regularly checking their systems so any problems are detected and remedied promptly, unlike in this case."

— Mark Steward, then Executive Director of Enforcement and Market Oversight, Financial Conduct Authority (FCA press release, March 28, 2019)

Why a 2019 transaction-reporting fine still frames the 2028 switch

This is not a MAR 14 case. On March 27, 2019 the FCA fined Goldman Sachs International £34,344,700 under section 206 of FSMA. Final Notice reference 142888 records a 30% settlement discount; without it the figure would have been £49,063,900. The Supervision manual breaches ran from November 5, 2007 to March 31, 2017. The press release of March 28, 2019 carries the Steward quotation. The notice carries the numbers.

Paragraph 2.2 says an estimated 204.1 million transactions were reported inaccurately, 9.5 million reportable transactions were not reported, and 6.6 million reports were erroneous. Paragraph 2.3 totals 220.2 million impacted reports, about 15% of roughly 1.5 billion reports sent in the period. The press line of 213.6 million is the first two populations added together.

Paragraph 2.6 is a Principle 3 finding: weak change management, weak detection controls and weak reference data. Self-reporting did not avoid the fine. Paragraph 3.12 of CP26/34 means a 2026 break is corrected after April 3, 2028 only on the new schema. MAR 14.15.4G sets a three-year default, keeps a five-year call for serious abuse cases, and leaves COBS 11 and Senior Management Arrangements, Systems and Controls (SYSC) 9 records at five years.

What this means for firms, venues and reporting mechanisms

An executing investment firm has three dates: comments by November 6, 2026, a final User Pack by April 3, 2027, and the schema switch on April 3, 2028. PS26/15's flexible approach from August 3, 2026 covers some populations, including EU-only instruments and, where UK European Market Infrastructure Regulation (EMIR) data are already filed, FX derivatives. It does not soften corrections. From go-live, a correction is a MAR 14 correction.

Qualifying venues share the window for reference data and for Article 26(5) reports on trades by non-reporting firms. PS26/15 already cut venue fields, tied to over 2,200 international firms in UK markets. CP26/34 adds package fields: field 3 for the venue code, and fields 31 and 38 for leg and package prices, or NOAP. A single-price complex trade is the concept being dropped.

CSSR stays optional, and neither PS26/15 nor CP26/34 scores a saving for it. Fund managers are in scope only as reporting firms, or where a venue reports for them. Moved cross-references alone should not force builds. The post-2028 correction format should. Question 11 is how a gap enters the 2027 pack. Annex 3 expects no new routine report.

"Unlike the transitions in November 2007 and January 2018, the proposed arrangements would mean corrections to historical transactions submitted after 3 April 2028 need to use the new format. That creates an interesting practical issue for firms with historical reporting problems still being investigated or remediated as implementation of the new regime gathers pace. Historical remediation could become a huge implementation problem if remediation and the transition to the new regime are running in parallel."

— Matthew Vincent, Managing Director, MiFIR Transaction Reporting, Kaizen (Kaizen, October 8, 2026)

What is still open before April 3, 2028

Comments close on November 6, 2026, across 14 questions on Level 3 texts, XML, the seven topics, transition and FIRDS. Paragraph 1.4 promises a date for MDP industry testing and does not give it. The further User Pack consultation comes before the April 3, 2027 final text, so the field rules are not frozen at publication of CP26/34.

Early removal of EU-only instruments from FIRDS waits on the Treasury repeal. If that slips, the only relief is the PS26/15 supervisory flexibility, which the consultation says FIRDS-led firms will barely feel. The made rules also note that the Handbook meaning of "working day" changes on March 18, 2027 under FCA 2026/6, before the User Pack deadline. CP26/34 does not explain that instrument.

PS26/15 Chapter 2 says the FCA may diverge from ESMA's July 2026 simplification report where UK data quality warrants it. The ESMA news page is not a UK start date. Commodity Futures Trading Commission (CFTC) relief for UK swaps into 2027 does not govern MAR 14 either. The FCA refused a two-year back-report. MAR 14.15.4G states three. April 3, 2028 is not offered as movable.

TL;DR

CP26/34 opened on October 2, 2026 and closes on November 6, 2026. It consults on rules made in PS26/15, in force on April 3, 2028, when UK MiFIR formats stop. The Transaction Reporting User Pack is due by April 3, 2027. Corrections from go-live use MAR 13, MAR 14 and MAR 15, including older trades. MAR 14.5.1R sets 23:59:59 UTC on the following working day. Default back-reporting falls from five years to three under MAR 14.15.4G. PS26/15 puts the annual cost of UK MiFIR transaction reporting at £493 million and ongoing savings at £115.3 million a year. EU Article 26 and the US Consolidated Audit Trail remain separate duties.

FAQ

What is FCA CP26/34?

CP26/34 is the FCA consultation "Preparing for the new transaction reporting regime", published on October 2, 2026. It asks for views on guidance, transitional provisions and Handbook amendments for rules already made in PS26/15. It does not reopen which products are in scope. Comments close on November 6, 2026. Draft schema and validation rules were published with the paper. A final Transaction Reporting User Pack is due by April 3, 2027, after a further consultation in the first quarter of that year.

When does the new UK regime start?

The rules come into force on April 3, 2028. CP26/34, paragraph 3.1, says FCA systems switch that day to a new schema and that UK MiFIR formats stop being accepted. PS26/15 describes a flexible supervisory approach from August 3, 2026 until then for specified populations. That approach is not a later start date. Once MAR 14.5.1R is in force, the report is due by 23:59:59 UTC on the following working day.

How are pre-2028 trades corrected?

From April 3, 2028, CP26/34 paragraph 3.12 says corrections of transaction reports and instrument reference data must comply with MAR 13, MAR 14 and MAR 15, including where the original event was earlier. The firm need not add information UK MiFIR did not require at the time. Pre-go-live order and transaction records need not be reformatted to MAR 13. Trades executed from March 31, 2028 through April 2, 2028 can still use the old format if the report is in before the switch.

How does this differ from EU MiFIR Article 26?

Article 26(1), in the text adopted on May 15, 2014, requires a complete and accurate report no later than the close of the following working day. The adopted scope includes instruments traded on a trading venue and specified underlyings, on-venue or off. Article 26(3) includes a short-sale designation the UK is removing. The UK replacement is MAR 14 from April 3, 2028, with a 23:59:59 UTC deadline and 52 fields rather than 65. CP26/34 plans to withdraw the EU Level 3 reporting texts for UK purposes in April 2028.

How does the US Consolidated Audit Trail differ?

CAT is an SEC order-lifecycle regime under 17 CFR 242.613, not a MiFIR copy. Exchanges, a national securities association and their members report NMS-security order events to a central repository by 8:00 a.m. Eastern Time on the next trading day. Origination records include a Customer-ID and a CAT-Order-ID, and timestamps go at least to the millisecond. CAT does not use MAR 14's 52 fields and does not cover the FX derivatives PS26/15 took out of the UK regime. Civil penalties sit under Exchange Act Section 21B, 15 U.S.C. 78u-2.

Why cite the 2019 Goldman Sachs fine?

The Final Notice of March 27, 2019, reference 142888, fined Goldman Sachs International £34,344,700 under section 206 of FSMA for transaction-reporting failures from November 5, 2007 to March 31, 2017. It counts 220.2 million impacted reports. The case used the old SUP 17 rules, not MAR 14. It matters because the FCA treated weak change controls, reference data and testing as an integrity failure, and because CP26/34 requires post-2028 corrections of historic breaks in the new format. Settlement cut the penalty 30% from £49,063,900.

This article is informational analysis only and does not constitute legal, regulatory, tax, or investment advice. Regulatory frameworks change frequently and interpretation depends on facts and circumstances; primary documents and official regulator guidance always supersede summaries. Firms should consult qualified legal counsel and their relevant supervisory authority before taking any action based on the analysis above.