UK Transaction Reporting Harmonisation: The BoE and FCA Taskforce

On 18 September 2026 the Bank of England and the Financial Conduct Authority published the minutes and supporting slides from the first meetings of their Transaction and Post-trade Reporting Harmonisation Taskforce, held on 3 July 2026. The papers are the clearest public signal yet of where UK transaction reporting harmonisation is heading across UK MiFIR, UK EMIR and UK SFTR. For any firm that reports under all three regimes, this is the moment the design conversation opened, and the moment to start feeding evidence into it.

The taskforce is a joint Bank of England and FCA initiative with industry members, organised through three regulator-co-chaired working groups, whose role is to inform the authorities’ long-term approach to simplifying and aligning UK MiFIR, UK EMIR and UK SFTR reporting. The authorities describe their long-term harmonisation goal as reducing unnecessary duplication and ensuring reporting requirements are proportionate to their benefit, while maintaining their ability to gain the insights needed to support their respective statutory objectives. The taskforce has no decision-making power and its outputs are not binding on the authorities.

The aim is to help reporting teams decide what to track, what to prepare, and what not to over-build while the picture is still forming.

Related reading: UK MiFIR Transaction Reporting Reform (PS26/15)

A joint Bank and FCA review of UK transaction reporting regimes

The taskforce is a joint Bank of England and FCA initiative, and that shared ownership matters because responsibility for UK transaction and post-trade reporting is genuinely split. Under the two authorities’ memorandum of understanding on financial market infrastructure, the Bank owns the framework for derivatives reporting as it applies to recognised clearing houses, and for securities financing transaction reporting as it applies to recognised clearing houses and recognised central securities depositories. The FCA owns the reporting framework for all other counterparties, and the commodity position reporting regime sits with the FCA too. Neither authority can harmonise the regimes on its own, which is why a single taskforce with both names on the door was the sensible vehicle.

The subject matter is the UK’s own assimilated law, distinct from the EU regimes it was copied from. UK MiFIR, UK EMIR and UK SFTR are the onshored versions retained after Brexit, and they are diverging from their EU counterparts over time. That distinction is not pedantic. Under the Financial Services and Markets Act 2023, assimilated financial-services law is being revoked and restated inside the regulators’ own rulebooks, which is what gives the Bank and FCA the room to redesign these reporting frameworks instead of only amending inherited technical standards. When the minutes talk about redesigning a regime from first principles, that legal machinery is what makes it possible.

The stated purpose is narrow and worth putting in practitioner terms: the taskforce exists to inform the design of the authorities’ long-term approach to harmonising UK MiFIR, UK EMIR and UK SFTR reporting. It is a knowledge-building and option-shaping body without rule-making power. Any actual change would still come through the normal consultation process later.

Key dates for the harmonisation review

The review does not run to a fixed statutory clock, but a short calendar helps place it against the reporting changes firms are already absorbing:

• 30 September 2024: UK EMIR Refit reporting requirements took effect, with the back-reporting transition for outstanding trades ending on 31 March 2025.
• 21 November 2025: the FCA published CP25/32, its consultation on improving the UK transaction reporting regime, with responses due by 20 February 2026.
• 2 April 2026: the Bank and FCA invited market participants to apply to join the taskforce.
• 3 July 2026: the inaugural meetings of the Policy, Strategy and Architecture working groups.
• August 2026: the FCA finalised its near-term MiFIR transaction reporting reforms in PS26/15.
• 18 September 2026: the Bank and FCA published the July minutes and the data slides.
• After the 3 July 2026 inaugural meetings, the terms of reference provide that each working group will normally meet every two months, with meeting dates determined by its chair.

Read together, these dates draw a line between two tracks. PS26/15 contains final UK MiFIR reforms that firms should plan for now, but the new regime comes into force on 3 April 2028; the FCA is taking a flexible supervisory approach to some areas from 3 August 2026 until then. The taskforce is the longer-horizon, cross-regime redesign.

Three working groups, and who sits around the table

The taskforce runs through three working groups that met on the same afternoon at the FCA’s Stratford offices. The Policy working group is the main group, supported by a Strategy group and an Architecture group. Each is co-chaired jointly by senior FCA and Bank officials, and the day-to-day support comes from the FCA’s transaction and position reporting team and the Bank’s financial market infrastructure data team.

What gives the membership its weight is the spread of firms represented, not any single name. The rooms brought together buy-side asset managers, sell-side dealers, inter-dealer brokers and trading venues, central counterparties, trade repositories and reference-data providers, reporting technology vendors, and the main trade associations. Buy-side participation ran from large index managers to hedge funds. Sell-side coverage included the major global dealers. Post-trade infrastructure was represented by clearing houses such as LCH and ICE Clear Europe, and by trade repositories and data bodies including DTCC, Bloomberg and the Derivatives Service Bureau. Reporting-quality specialists such as Kaizen Reporting, Qomply and REGnosys sat alongside the trade bodies covering derivatives, securities lending, asset management and futures, among them ISDA, ISLA, AIMA, AFME and the FIA.

The division of labour is deliberate. The Policy group is focused on identifying where data collected under the three regimes could be harmonised and where reporting can be simplified. The Strategy group weighs pragmatic near-term simplification against a more fundamental redesign. The Architecture group looks at the plumbing: the cost and complexity of the current reporting infrastructure and what a better target design would look like. The minutes note that the three workstreams are interconnected and are meant to be considered together.

What the data-led session revealed about UK reporting volumes

Each group was shown the same data-led overview, built to give members a shared picture of the three regimes by volume, asset class and action type. The volumes below track the same regimes covered in our EMIR reporting guide and SFTR reporting explainer, in their UK form. The numbers are worth carrying into any internal discussion because they tell you where the reporting effort actually goes.

On UK EMIR, measured at transaction level since July 2025, commodity futures made up the largest share of activity reports at 41 per cent, followed by interest rate futures, equity futures and equity swaps. The trade state reports were dominated instead by interest rate swaps at 33 per cent and FX forwards at 22 per cent. The most striking figure was by action type: valuation updates accounted for 48 per cent of transaction-level activity reports, with position components a further 38 per cent, while genuinely new trades were around 2 per cent. Under UK SFTR, securities lending dominated the flow at 88 per cent of activity reports, and valuation updates again made up close to half of activity by action type at 45 per cent. On UK MiFIR, daily transaction reports since June 2025 were 67 per cent equities and equity-like instruments, with futures and forwards, ETFs, total return swaps and CFDs making up most of the rest.

One correction is worth making early, because the framing invites it. Harmonisation here does not mean folding the three regimes into a single return. The Architecture group said as much directly: harmonisation does not necessarily require combining regimes into one framework, and any future design would need to respect the distinct purposes each regime serves. The point of the shared data set is to find the overlaps worth removing, not to erase the boundaries.

“Report once” and the future of dual-sided reporting

The single idea that ran through all three rooms was report once. Members explored whether the authorities could receive certain information a single time instead of through duplicated reports across regimes, and whether data already held by financial market infrastructures could feed a more efficient model. When asked how many firms report across all three regimes, numerous members said their own firms sat in that population, which is the practical case for the whole exercise.

Dual-sided reporting is the sharpest question inside that idea. UK EMIR and UK SFTR use two-sided reporting for many in-scope transactions, but that does not mean every counterparty submits a separate report. Under UK EMIR, responsibility can rest with an entity responsible for reporting, including specified cases where a financial counterparty is solely responsible and legally liable for reporting on behalf of both counterparties. UK SFTR also permits delegated reporting and does not place UK non-financial counterparties within its UK reporting scope. The Policy group discussed the potential to move toward a single-sided model. Here the minutes are careful, and reporting teams should be too. Members noted real risk and complexity in moving away from dual-sided reporting: firms have already invested heavily in dual-sided systems, some want to keep reconciliation reports or visibility over both sides of a trade, and single-sided reporting is not automatically better because it removes a cross-check. Members also observed that dual-sided reporting does not guarantee data quality if both sides report the same trade incorrectly.

A second caution surfaced repeatedly, and it is the one most likely to be misread outside the room. Cutting reportable fields does not automatically cut cost. The Policy and Architecture groups both warned that reducing fields may deliver little saving if the underlying infrastructure across approved reporting mechanisms and trade repositories stays expensive to run, and that removing a field embedded deep in a firm’s systems can leave the complexity untouched. Members also flagged that harmonisation could redistribute cost between buy-side and sell-side firms, particularly if reporting responsibility shifts between counterparties. Firms should therefore model infrastructure and process costs alongside field-count changes when assessing the likely savings from any future proposal.

Valuation reporting and the case for golden data sources

Given that valuation updates make up close to half of daily action-type volumes under both UK EMIR and UK SFTR, it is no surprise the Strategy group spent time on them. Members discussed whether some valuation calculations could be performed centrally by the authorities or by relevant market infrastructure, rather than being computed and reported by every firm. They also drew out the awkward part of valuation reporting: mark-to-market and mark-to-model values differ methodologically, and members noted that the problems often come from the related data around a valuation, more than from the figure itself.

The companion idea is the golden data source. Members returned to the possibility of a universal dataset from which the authorities draw only what they need, and to reducing firms’ reliance on sourcing data from other market participants. A recurring frustration was that firms must often source reference data externally with limited ability to validate it, then reproduce the same information in different formats for different regimes, incurring transformation and reconciliation cost each time. Better use of established standards and identifiers, ISO standards, ISINs, CFIs and unique product identifiers among them, was raised as a route to more consistent data across regimes and jurisdictions.

Valuation reporting should therefore be treated as an area to monitor rather than as a decided first step. The taskforce has no decision-making responsibility, and any future change would need to proceed through the authorities’ applicable policy process.

Where the UK review meets ESMA’s EU work

International alignment was a live theme in every group, driven by the number of members that report across jurisdictions. ESMA published its final report on simplifying EU transaction reporting on 2 July 2026 and is now engaging with EU institutions on its recommendations; implementation of its proposed integrated ‘report once’ approach would require legislative changes. The UK taskforce is a separate process. The stated posture is pragmatic: UK reforms should stay internationally compatible where possible, and divergence should not be pursued for its own sake, though it may be justified where it supports the objectives of the UK framework.

This is where the Brexit reality bites for reporting teams. UK MiFIR, UK EMIR and UK SFTR are already distinct from the EU regimes, and this taskforce is a UK exercise, separate from ESMA’s. A change agreed in Brussels does not flow automatically into the UK returns, and the reverse holds too. Firms watching both should track the two reviews as related but independent, because the operational risk is a design that drifts far enough from the EU model to force a second, parallel build for cross-border books. You can follow the EU side through ESMA’s transaction reporting simplification of EMIR, MiFIR and SFTR, which covers the same three-regime problem from the EU angle.

What the taskforce does not change (yet)

It is worth stating plainly what has not happened, because early-stage reviews are easy to over-read. The taskforce has proposed no rule change, published no consultation of its own, and created no new reporting obligation. The July papers are minutes of exploratory discussion and a shared data set. Nothing in them alters what firms report under UK MiFIR, UK EMIR or UK SFTR, or when they report it.

The separate MiFIR track has reached final policy in PS26/15. When the new regime comes into force on 3 April 2028, the final rules will reduce the number of UK MiFIR transaction-reporting fields from 65 to 52 and reduce the default back-reporting period from five years to three, alongside other simplifications. Firms should plan for that implementation now; the FCA is taking a flexible supervisory approach to some areas from 3 August 2026 until commencement. The taskforce, by contrast, is exploring longer-term options; its outputs are non-binding and do not replace the authorities’ formal consultation mechanisms.

The homework the Architecture group set its members captures the spirit of the exercise. They were asked to describe an ideal reporting architecture without immediate implementation constraints, and to sketch how they would design UK EMIR, UK SFTR and UK MiFIR reporting if starting from first principles. That homework is a strong signal: a firm’s transaction reporting strategy for the second half of the decade is being drafted now, in a room firms can influence.

Frequently Asked Questions

Does the taskforce change what my firm reports today?

No. The taskforce has no decision-making power and creates no new reporting obligation. PS26/15 is a separate FCA process: its new UK MiFIR regime comes into force on 3 April 2028, with a flexible supervisory approach applying to some areas from 3 August 2026 until then.

Which regulator owns which regime, and who do I actually report to?

UK MiFIR transaction reports are submitted to the FCA’s Market Data Processor either directly by an investment firm, by an approved reporting mechanism on its behalf, or by a trading venue on behalf of entities executing through its systems. UK EMIR and UK SFTR reports are submitted to FCA-registered or recognised trade repositories. Under the Bank and FCA memorandum of understanding, the Bank owns the derivatives and SFT reporting frameworks as they apply to recognised clearing houses and, for SFTs, recognised central securities depositories, while the FCA owns the reporting framework for all other counterparties.

Are UK MiFIR, UK EMIR and UK SFTR the same as the EU regimes?

No. They are the UK’s assimilated versions retained after Brexit, and they are being restated in the regulators’ own rulebooks under the Financial Services and Markets Act 2023. They already differ from the EU regimes in places, and the taskforce is a UK exercise separate from ESMA’s EU work.

How is this different from CP25/32 and PS26/15?

CP25/32 was the consultation; PS26/15 contains the final UK MiFIR rules. The new regime comes into force on 3 April 2028 and will include fewer reportable fields and a shorter default back-reporting period. The taskforce is separate, longer-term work on harmonising UK MiFIR, UK EMIR and UK SFTR and has no decision-making power.

Would a “report once” model mean my firm stops reporting to a trade repository?

Not necessarily. Report once was discussed as a concept, covering ideas such as receiving certain information a single time, drawing on data already held by financial market infrastructures, and reducing duplication across regimes. The minutes describe options, not decisions. Any move in that direction would be consulted on separately and would have to preserve the distinct purposes each regime serves.

Does harmonisation help or hurt smaller firms and those using delegated reporting?

The taskforce flagged both. Members noted that smaller firms can inherit reporting burdens when accessing liquidity, and that delegated reporting carries its own cost. They also warned against one-size-fits-all designs and discussed threshold-based approaches to tailor requirements. Whether smaller firms end up better off depends on choices that have not yet been made.

Can my firm feed views in if it is not a taskforce member?

The authorities have published the current taskforce membership, but the terms of reference allow them to review membership as necessary. The taskforce does not replace the authorities’ formal consultation mechanisms. The practical route for a non-member is to prepare evidence on where duplication, dual-sided reporting and valuation reporting cost the most, and to respond when the authorities consult. Industry associations on the taskforce, such as ISDA, ISLA, AIMA, AFME and the FIA, are also channels for input.

Related Articles

• UK MiFIR Transaction Reporting Reform (PS26/15): the near-term FCA changes to UK MiFIR transaction reporting, including the reduction in reportable fields and the 3 April 2028 commencement date.
• BoE and FCA FMI Memorandum of Understanding: how the Bank and FCA split responsibility for UK derivatives and SFT reporting.
• ESMA Transaction Reporting Simplification (EMIR, MiFIR, SFTR): ESMA’s 2 July 2026 final report on simplifying EU transaction reporting across MiFIR, EMIR and SFTR.
• EMIR Reporting Explained: a practitioner walkthrough of derivatives reporting to trade repositories.
• SFTR Reporting Explained: how securities financing transaction reporting works and who has to file it.

Key Takeaways

• The Bank of England published the first taskforce minutes on 18 September 2026, covering inaugural meetings held on 3 July 2026; the terms of reference provide that each working group will normally meet every two months.
• The taskforce covers UK MiFIR, UK EMIR and UK SFTR through three groups: Policy (main), Strategy and Architecture. It creates no new reporting obligation.
• PS26/15 contains the final near-term UK MiFIR reforms: when the new regime comes into force on 3 April 2028, reportable fields will reduce from 65 to 52 and the default back-reporting period will reduce from five years to three. The FCA is taking a flexible supervisory approach to some areas from 3 August 2026 until then.
• Report once, single-sided reporting, central valuation calculation and golden data sources are the main levers under discussion; none is decided.
• Valuation updates are close to half of daily action-type volumes under both UK EMIR and UK SFTR, making valuation reporting the most measurable target for early simplification.
• Fewer fields will not automatically cut cost if approved reporting mechanism and trade repository infrastructure stays expensive; harmonisation can also shift cost between buy-side and sell-side.
• UK regimes are distinct from their EU counterparts; track EU follow-up to ESMA’s 2 July 2026 final report separately from the UK taskforce.
• Assemble internal evidence now on duplication, dual-sided reporting and valuation cost so it is ready when the authorities consult.

Sources and References

• Bank of England, Minutes of the Transaction and Post-trade Reporting Harmonisation Taskforce, July 2026 (published 18 September 2026).
• Bank of England and FCA, Policy Working Group meeting minutes, 3 July 2026.
• Bank of England and FCA, Strategy Working Group meeting minutes, 3 July 2026.
• Bank of England and FCA, Architecture Working Group meeting minutes, 3 July 2026.
• Bank of England and FCA, Harmonisation Taskforce slides: overview of UK MiFIR, UK EMIR and UK SFTR reporting.
• Bank of England and FCA, Terms of Reference for the Transaction and Post-trade Reporting Harmonisation Taskforce (2 April 2026).
• FCA, FCA and Bank appoint members to their Transaction and Post-trade Reporting Harmonisation Taskforce.
• Bank of England and FCA, Memorandum of Understanding on the supervision of financial market infrastructure (July 2025).
• FCA, CP25/32: Improving the UK transaction reporting regime (21 November 2025).
• FCA, PS26/15: Improving the UK transaction reporting regime (August 2026; new regime in force 3 April 2028).
• FCA, UK EMIR reporting obligation and UK EMIR Refit reporting changes (effective 30 September 2024).
• ESMA, Final Report on the Call for Evidence on a comprehensive approach for the simplification of financial transaction reporting, ESMA12-1406959660-3235 (2 July 2026).

What to watch as the taskforce review develops

The taskforce has done the easy part: it has agreed a shared picture of how much firms report, in what, and how often. The taskforce remains at an exploratory stage, and its terms of reference give it no decision-making responsibility. Reporting teams should therefore distinguish current obligations and final rules from longer-term harmonisation options that may emerge through the authorities’ subsequent policy process. Capture where duplication, externally sourced reference data and valuation reporting cost the most across your UK MiFIR, UK EMIR and UK SFTR flows, so that when the authorities consult, your evidence is already written down and your firm argues from data.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.