We use transaction reports to detect and investigate market abuse. Read more about the regime and whether you need to submit transaction reports.
UK MiFIR transaction reports must be submitted following the execution of a transaction in a reportable instrument. Transaction reports include information on the instrument traded, the price, and the participants involved.
The requirement to submit transaction reports is contained in Article 26 of UK MiFIR[1]. This is supplemented by applicable guidance on the transaction reporting regime.
Complete and accurate transaction reports play a critical role in our ability to monitor markets. Transaction reports are also used to conduct supervision and support the work of other regulatory authorities such as the Bank of England.
The Markets Reporting Team (MRT) is responsible for monitoring the quality of transaction reporting data. The MRT is also responsible for supervising firms’ compliance with transaction reporting requirements and for developing transaction reporting rules.
Our transaction reporting resources[2] page includes more on applicable regulatory materials, updates and relevant Market Watch newsletters.
Who needs to submit a transaction report
This depends on the activity conducted by a firm. In general, the following categories of firms are required to submit transaction reports:
- UK MiFID investment firms excluding collective portfolio management investment firms.
- Operators of a trading venue (recognised investment exchanges, multilateral trading facilities (MTFs) and organised trading facilities (OTFs)).
- UK branches of third country investment firms.
- Small Authorised UK AIFMs with MiFID permissions.
- UK CRD Credit institutions.
For principal firms with appointed representatives (ARs), the obligation to report sits with the principal firm in relation to any reportable activity conducted by its ARs.
Under Article 26(7) of UK MiFIR transaction reports can only be submitted by:
- an investment firm submitting their own reports directly to the FCA’s Market Data Processor (MDP)[3]
- an Approved Reporting Mechanism (ARM) acting on behalf of an investment firm
- a trading venue who submits on behalf of entities executing through its systems
When a transaction is reportable
Under Article 26(1) UK MiFIR an investment firm must submit transaction reports for transactions it executes in financial instruments. An investment firm is deemed to have executed a transaction where it provides any of the services set out in Article 3 of RTS 22. The scope of these instruments is set out in Article 26(2) UK MiFIR.
If you're not sure whether you need to submit transaction reports, answer the questions below.
The obligation to submit a transaction report applies irrespective of whether the transaction took place on a trading venue.
UK investment firms have a responsibility to determine whether an instrument they have traded is a reportable financial instrument.
RTS 22 Article 15(1)(g) and (h) require firms to have mechanisms in place to avoid reporting any transaction where there is no obligation to report, and to identify any unreported transactions for which there is an obligation to report.
Reconciliation of transaction reports
Article 15(3) of RTS 22 requires investment firms to ensure their transaction reports are complete and accurate.
We expect investment firms to have processes to regularly reconcile their front-office records against data samples from our Market Data Processor (MDP) entity portal[5].
Submitting errors and omissions notifications
An errors and omissions notification must be submitted via Connect[6] if your firm becomes aware of any error or omission in its transaction reports, including the failure to submit a transaction report.
Notifications should be comprehensive, including adequate detail to facilitate our review of the incident. Subsequent updates to previously submitted notifications should be emailed to [email protected] quoting your submission reference number.
If your firm is not registered for Connect please see our Connect registration page[7]. If your firm is registered for Connect, and you require additional users, please refer to our Connect user management guide[8].
Back reporting
Under Article 26(7) of UK MiFIR, where errors or omissions are identified in transaction reports, the ARM, investment firm or trading venue reporting the transaction must:
- cancel the report
- correct the information
- submit a corrected report to us
The trade date within a transaction report cannot be earlier than 5 years before the submission date. As such, from 3 January 2023 onwards, transaction reports submitted with a trade date of more than 5 years ago will not be accepted.
Errors and omissions notifications should continue to contain details of when the error or omission first occurred and the number of transaction reports impacted, even if this extends beyond 5 years. Firms should then indicate how many of the impacted transaction reports will be back reported.
