Information on Mifid II transaction reporting/EMIR Reporting - March 2026

Between 1 January 2025 and 31 December 2025, the FCA commissioned no skilled person reviews to address MiFID II or EMIR reporting issues.

Between 1 January 2025 and 31 December 2025, the FCA imposed no voluntary or own initiative requirements on firms in response to MiFID II or EMIR reporting issues.

Between 1 January 2025 and 31 December 2025, 882 firms accessed the FCA’s MDP Entity Portal to request a transaction reporting data extract.  A total of 1,171 UK investment firms were identified as an executing entity in a transaction report submitted to the FCA during the same period.

Under Article 15(3) of RTS 22, investment firms must have arrangements in place to ensure their transaction reports are complete and accurate.  Those arrangements should include regular reconciliations of front office trading records against data samples provided by the FCA.  We expect all firms to meet their obligations under RTS 22.

We conduct periodic, risk-based thematic work to improve the completeness, accuracy and frequency of reconciliations conducted by firms under Article 15(3) of RTS 22.  We wrote to 8 UK investment firms in 2025 to enquire why no reconciliations had been conducted. None of these firms were subject to a VREQ or OIREQ. 

There are currently 2,616 firms with UK MiFID permissions. While this far exceeds the number of firms that have been identified as an executing entity in a transaction report submitted to the FCA, our records indicate that many of these firms have not executed transactions in reportable financial instruments.

We conduct regular work to identify firms which have not submitted transaction reports in line with regulatory requirements.  We use transaction reports and other sources of intelligence to identify firms that may have executed transactions in reportable financial instruments.  We combine this information with other sources of data to identify firms that may have failed to comply with reporting obligations.  In 2025, we assessed 266 instances of potential unreported transactions under MiFIR, involving 173 unique firms.

Between 1 January 2025 and 31 December 2025, the FCA opened no enforcement operations or investigations into compliance with MiFID II or EMIR reporting requirements.

We continue to take compliance with transaction reporting requirements seriously. In January 2025, we fined Infinox Capital Limited[1] £99,200 for failing to submit 46,053 transaction reports.  In August 2025, we fined Sigma Broking Limited[2] £1,087,300 for failing to submit complete and accurate transaction reports for 5 years.  These outcomes demonstrate the importance of transaction reporting data quality