United Kingdom: Recent issues flagged by the FCA in the transaction reporting space

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.


Contents

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.

To read our alert, click here.

*****

Thomas Blott, Trainee, has contributed to this legal update.

Contact Information

Copyright © 2025 Baker & McKenzie. All rights reserved. Ownership: This documentation and content (Content) is a proprietary resource owned exclusively by Baker McKenzie (meaning Baker & McKenzie International and its member firms). The Content is protected under international copyright conventions. Use of this Content does not of itself create a contractual relationship, nor any attorney/client relationship, between Baker McKenzie and any person. Non-reliance and exclusion: All Content is for informational purposes only and may not reflect the most current legal and regulatory developments. All summaries of the laws, regulations and practice are subject to change. The Content is not offered as legal or professional advice for any specific matter. It is not intended to be a substitute for reference to (and compliance with) the detailed provisions of applicable laws, rules, regulations or forms. Legal advice should always be sought before taking any action or refraining from taking any action based on any Content. Baker McKenzie and the editors and the contributing authors do not guarantee the accuracy of the Content and expressly disclaim any and all liability to any person in respect of the consequences of anything done or permitted to be done or omitted to be done wholly or partly in reliance upon the whole or any part of the Content. The Content may contain links to external websites and external websites may link to the Content. Baker McKenzie is not responsible for the content or operation of any such external sites and disclaims all liability, howsoever occurring, in respect of the content or operation of any such external websites. Attorney Advertising: This Content may qualify as “Attorney Advertising” requiring notice in some jurisdictions. To the extent that this Content may qualify as Attorney Advertising, PRIOR RESULTS DO NOT GUARANTEE A SIMILAR OUTCOME. Reproduction: Reproduction of reasonable portions of the Content is permitted provided that (i) such reproductions are made available free of charge and for non-commercial purposes, (ii) such reproductions are properly attributed to Baker McKenzie, (iii) the portion of the Content being reproduced is not altered or made available in a manner that modifies the Content or presents the Content being reproduced in a false light and (iv) notice is made to the disclaimers included on the Content. The permission to re-copy does not allow for incorporation of any substantial portion of the Content in any work or publication, whether in hard copy, electronic or any other form or for commercial purposes.