MiFIR transaction reporting is undergoing significant changes on both sides of the Channel. The EU’s MiFIR Review in 2024 introduced new reporting requirements and mandates, while the UK is charting its own post-Brexit course.
Below is a curated list of official documents - EU legislation, ESMA papers, and UK FCA publications to help you understand the evolving landscape.
This is the first in a three-part blog series exploring the upcoming changes to MiFIR transaction reporting in the EU and UK. Stay tuned for our next blog, where we’ll break down the timeline of what’s coming and when.
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Contents
Key EU Documents
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This EU amending Regulation (part of the MiFID II/MiFIR review package) took effect on 28 March 2024. It revises MiFIR’s Article 26, expanding the scope of transactions to be reported - notably bringing certain centrally-cleared OTC derivatives into scope regardless of trading venue.
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The regulation also mandates ESMA to develop updated technical standards to reflect the new reporting rules.
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Secondary sources:
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The companion directive in the 2024 MiFID II/MiFIR review package, which also entered into force on 28 March 2024. While largely focused on other areas of market structure, this directive complements the MiFIR changes. EU Member States must transpose these MiFID II amendments by 28 September 2025.
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ESMA’s consultation paper proposing changes to the MiFIR transaction reporting technical standards, in light of the 2024 MiFIR reforms. Key proposals include new reportable fields (e.g. “transaction effective date” and identification of the reporting entity) and new identifiers to link related trades, revisions to existing fields to align with EMIR/SFTR and international standards, and refined rules for determining the competent authority for certain trades.
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Critically, the paper details how MiFIR’s scope is broadened for derivatives - e.g. certain cleared interest rate and credit derivatives must be reported even if OTC, while other OTC derivatives only require reporting when traded on-venue.
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ESMA expects to finalize and submit the revised RTS to the European Commission in Q1 2025.
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In this statement, ESMA provides guidance on how firms should handle new MiFIR obligations pending the update of technical standards.
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It clarifies that until the revised RTS/ITS are in force, existing reporting rules and formats remain applicable.
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In practice, this means investment firms must continue using the current MiFIR transaction reporting schema (Commission Delegated Regulation (EU) 2017/590) until the new standards apply. The statement, alongside a European Commission interpretative notice, ensures firms have sufficient lead time for IT changes and that there is no gap in compliance during the transition to the new regime.
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Secondary sources:
Firms should carefully track ESMA’s finalization of new technical standards in early 2025, as these will clarify exact reporting formats and timelines. Until new rules are in effect, existing reporting standards remain applicable, meaning immediate changes are minimal - but substantial system adjustments are expected by late 2025 or early 2026.
Key UK Documents
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Announced as part of the UK’s Wholesale Markets Review follow-up, this policy outlines the government’s plan to overhaul MiFID-derived requirements.
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Notably, HM Treasury intends to revoke the UK’s retained EU MiFIR provisions on transaction reporting and hand rulemaking authority to the FCA.
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The goal is to allow the FCA to design a more tailored UK regime, resolving issues identified during the Wholesale Markets Review.
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This sets the stage for changes in who reports and what data is reported in the UK, in line with broader capital markets reforms.
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Secondary sources:
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In conjunction with HM Treasury’s move, the FCA published this discussion paper seeking industry input on a future UK transaction reporting framework.
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The FCA’s objectives are twofold: enhance data quality for market oversight and reduce unnecessary burdens on firms.
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The DP canvasses views on several areas, including: potential elimination of duplicative fields (especially where UK MiFIR overlaps with UK EMIR trade reporting), use of standardized product identifiers (ISO 4914 UPI) for OTC derivatives, and possibly bringing certain currently out-of-scope entities into the regime.
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Notably, the FCA is evaluating whether to extend transaction reporting to UK AIFMs and UCITS managers for their MiFID-scope activities (these managers are not currently reporters). It also questions the value of each data field in the report, asking which fields truly serve regulatory goals and whether new fields are needed.
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Feedback on DP24/2 was open until 14 February 2025, and the FCA will use industry responses to shape detailed rule proposals (a formal consultation is expected in 2025).
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Secondary sources:
UK firms can expect more streamlined, possibly divergent transaction reporting rules from the EU, including potential removal of duplicative fields and clearer reporting obligations. Stakeholder feedback gathered through early 2025 will shape detailed proposals expected later this year, with final rules likely implemented in 2026.
IMplementation timeline and Next Steps
Both the EU and UK have established phased timelines to implement their respective transaction reporting reforms. While EU changes began with legislation in early 2024, substantial practical reporting updates are expected around late 2025 to early 2026. The UK’s timeline follows a similar but slightly delayed path, with FCA rule proposals expected during 2025.
EU Timeline
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The revised EU rules under the MiFIR Review are not a “big bang” change on day one. Many new obligations will phase in over coming years.
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Article 54(3) of MiFIR (as amended) provides that existing Level 2 acts stay in force until replaced.
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Practically, this means firms will continue reporting under the current schema and field definitions until the new RTS are adopted and become applicable.
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ESMA has indicated it will align the timing of new requirements with necessary IT system updates and will communicate expected go-live dates once the technical standards are finalized.
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Compliance teams should monitor ESMA’s updates in 2025 for the approval of the revised RTS 22/24 and any related implementing technical standards.
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A reasonable expectation is that the new EU transaction reporting format and fields will go live in late 2025 or 2026, after a sufficient implementation period following the Commission’s adoption of the RTS.
UK Timeline
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The UK is at an earlier stage of reform in comparison to the EU.
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HM Treasury’s legislative changes to repeal the old regime will likely coincide with the Financial Services and Markets Act updates in 2024/2025, empowering the FCA to set new rules.
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The FCA’s DP24/2 is a first step; specific rule changes and an implementation schedule will emerge only after the FCA consults on proposed rules, expected in 2025 once HM Treasury’s revocation takes effect.
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Firms in the UK can anticipate a lead time to adjust systems once the new FCA-defined regime is announced. In the interim, the status quo remains - UK firms must keep reporting under the existing UK MiFIR framework (which mirrors the EU’s pre-2024 model) until any new rules are formally in place.
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We look forward to supporting you through these changes!
