The opinions expressed here are those of the authors. They do not necessarily reflect the views or positions of UK Finance or its members.

They reflect a broader shift in how the FCA views regulatory data: what it collects, how it uses it, and what it expects from firms.

As the FCA states in CP25/32:

“We want to clarify and streamline transaction reporting requirements so firms can improve the quality of data they submit.”

While the proposals aim to reduce cost and complexity, they also underline a deeper reality: regulators are relying more heavily than ever on transaction data, and that reliance brings greater scrutiny.

From compliance obligation to strategic data asset

Historically, transaction reporting was primarily about identifying market abuse. Today, the FCA frames it as a strategic regulatory data asset that supports multiple functions across supervision, enforcement and policy.

The paper set out an expanded set of uses for transaction reporting data:

• Market abuse and financial crime: Detecting and investigating market abuse remains central, but reporting is also increasingly linked to financial crime prevention.
• Market monitoring: Transaction data supports the FCA’s understanding of how markets function in practice, including liquidity, trading behaviour, disruptions and resilience.
• Direct supervision: Reporting data is used to identify risk signals, weaknesses in controls and compliance failings, influencing supervisory priorities and engagement with firms.
• Policy evaluation: Transaction reports help the FCA, Bank of England and PRA assess how rules affect market behaviour and whether regulatory reforms are working as intended.
• Market stress and stability: During periods of stress, timely and complete data is critical for assessing liquidity pressures, volatility and disorderly market conditions.
• Data sharing: Transaction data is shared across authorities, reinforcing that reporting quality feeds into wider financial stability intelligence, not just FCA supervision.

In short, transaction reporting sits at the centre of how regulators understand and oversee markets.

CP25/32: less data, more focus

Against this backdrop of expanding use, CP25/32 proposes a meaningful reduction in what firms must report. Key changes include:

• Reducing the number of reporting fields from 65 to 52
• Removing the obligation to report around six million EU-only instruments
• Removing FX derivatives from scope
• Shortening the default back-reporting period from five years to three
• Removing the obligation to report corporate actions
• Providing clearer guidance on complex areas, such as swaps, to improve consistency

Together, these changes aim to create a more targeted and proportionate dataset aligned with what the FCA genuinely needs, while removing unnecessary complexity.

Simpler reporting, higher expectations

A consistent theme in CP25/32 is that simpler rules should lead to better data. The FCA’s logic is clear: reducing complexity allows firms to focus their resources on getting the remaining data right.

The FCA explicitly expects improvements in data quality and signals how it will assess them, including through acceptance rates, error alerts and corrective reporting trends. Removing low-value fields, narrowing scope and clarifying guidance should reduce misinterpretation, operational failures and remediation cycles. In turn, this should reduce follow-up data requests and improve efficiency for both firms and the regulator.

However, simplification does not mean reduced scrutiny. If anything, the opposite is true.

Competitiveness without deregulation

These reforms, expected to be implemented by early 2028, reflect the FCA’s competitiveness and growth objective. This is not about weakening standards, but about making regulation more effective and proportionate while remaining firmly anchored in market integrity and consumer protection.

The direction of travel is clear. The FCA is streamlining transaction reporting while increasing its reliance on the data it receives. Firms should view CP25/32 as simplification, not deregulation: a reduced burden paired with sharper expectations on quality.

There are clear benefits for industry, but they come with a message that should not be missed. As transaction reporting becomes more central to supervision and policy, firms will be judged increasingly on the quality, accuracy and timeliness of the data they provide.