In brief
Transaction reporting issues have been high on the agenda for some time, both for the regulators and financial institutions. Over the past year, the Financial Conduct Authority (FCA) has published its reviews and observations on firms’ behaviours and practices in the transaction reporting space through a number of editions of Market Watch, its newsletter on market conduct and transaction reporting issues. Market Watch 82 (23 July 2025) sets out the FCA’s recent observations from supervising the UK Markets in Financial Instruments Directive (MiFID) transaction reporting regime. This was then followed by Market Watch 84 (30 September 2025) with observations on the implementation of UK European Market Infrastructure Regulation (EMIR) Refit requirements, which made changes to the UK EMIR reporting regime and took effect in September 2024.
The FCA’s observations in both editions of Market Watch will be of interest to firms subject to the transaction reporting requirements under any of the UK EMIR, Securities Financing Transactions Regulation (SFTR) and MiFID regimes, and will be helpful reading for compliance officers and legal teams that have recently been through the process of filing an Errors and Omissions (E&O) notification form with the FCA, or indeed the laborious process of back reporting transaction reports that were filed with inaccurate or incomplete data.
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Thomas Blott, Trainee, has contributed to this legal update.