1. Do you need to report?
Transaction reporting tells the FCA about every trade your firm carries out in certain financial instruments, so that it can look for market abuse and monitor the market. The rules are in UK MiFIR (Article 26) and the FCA's technical standards.
Who reports
An investment firm that executes a transaction reports it. "Executes" is wider than it sounds, as it includes:
- buying or selling for your own account;
- buying or selling for a client, as agent;
- making the investment decision for a client under a discretionary mandate, even if a broker then places the order.
If you only pass a client's order to another firm and meet the conditions for "transmitting" an order (you send the other firm everything it needs to report), that other firm reports it instead of you. Small firms often rely on this. If you do, check that the arrangement is in writing and that the receiving firm really does report on your behalf.
Which instruments
Broadly, instruments admitted to trading or traded on a trading venue, and derivatives whose underlying is one of those. That covers listed shares, bonds, exchange-traded funds and listed derivatives, and also over-the-counter products such as CFDs and spread bets on shares or indices.
From 3 April 2028 the FCA narrows the scope to instruments on UK venues and removes FX derivatives. Until then, instruments on EU venues are also in scope.
When
By the end of the working day after the trade (T+1). Late reports still need to be sent, so report them as soon as you find them.
What this service does
You tell us about each trade, in our template or on the single-report form. We check it, send it to DTCC (an Approved Reporting Mechanism, or ARM), and DTCC passes it on to the FCA. DTCC's and the FCA's answers come back to you here.
You stay responsible for your reporting, which means your reports being complete, accurate and on time. We have designed the service to make that as hard as possible to get wrong.
Still unsure?
If you are not sure what your firm should be reporting, or whether your current reporting is right, talk to our professional services team, with no obligation, at support@regulatoryadvice.co.uk.
Next: 2. Anatomy of a report
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