# FCA PS26/15: what changes in UK transaction reporting for CFD brokers, and when **Status:** final policy statement, rules apply from 3 April 2028. Last checked 3 November 2026. This page explains a public document. It is not legal or regulatory advice. **Short answer:** PS26/15, published by the FCA on 3 August 2026, simplifies UK MiFIR transaction reporting from 3 April 2028. FX derivatives leave transaction reporting, with UK EMIR as their reporting route. Reportable fields fall from 65 to 52 and the back-reporting window from five years to three. CFDs and cryptoasset derivatives stay in scope, so most CFD brokers still report. ## Key dates | Date | What happens | Source | |---|---|---| | 3 August 2026 | PS26/15 published; the FCA applies a flexible supervisory approach for firms moving early | [CMS](https://cms.law/en/gbr/regulatory-news/fca-ps26-15-improving-the-uk-transaction-reporting-regime), [HLC](https://hlc.com/en/publications/the-uk-streamlines-transaction-reporting-requirements) | | October 2026 | Draft schema and validation rules expected | [KPMG](https://assets.kpmg.com/content/dam/kpmgsites/in/pdf/2026/10/fca-transaction-reporting-update-key-changes-in-ps26-15.pdf) | | 3 April 2028 | New regime applies | [HLC](https://hlc.com/en/publications/the-uk-streamlines-transaction-reporting-requirements), [Finance Magnates](https://www.financemagnates.com/forex/regulation/fca-cuts-108-million-a-year-from-reporting-costs-but-keeps-cfds-in-scope/) | ## What changes ### FX derivatives leave UK transaction reporting FX derivatives are removed from the scope of UK MiFIR transaction reporting. The FCA's reasoning, as reported, is that UK EMIR data is the better source for monitoring FX derivatives, and that MiFIR reports partly duplicated it ([FCA](https://www.fca.org.uk/publications/policy-statements/ps26-15-improving-uk-transaction-reporting-regime); [The Industry Spread](https://theindustryspread.com/fca-fx-derivatives-uk-transaction-reporting-2028/); [FX News Group](https://fxnewsgroup.com/forex-news/regulatory/fca-to-remove-fx-derivatives-from-scope-of-transaction-reporting-regime/)). ### Fewer fields Reportable fields fall from 65 to 52, about a fifth fewer ([Finance Magnates](https://www.financemagnates.com/forex/regulation/fca-cuts-108-million-a-year-from-reporting-costs-but-keeps-cfds-in-scope/)). ### A shorter back-reporting window Firms correcting errors must back-report three years instead of five. Finance Magnates reports the FCA expects about a third fewer resubmitted reports as a result ([Finance Magnates](https://www.financemagnates.com/forex/regulation/fca-cuts-108-million-a-year-from-reporting-costs-but-keeps-cfds-in-scope/)). ### Lower industry cost Finance Magnates reports an estimated net saving of about £108 million a year across the industry; other coverage rounds it to £100 million ([Finance Magnates](https://www.financemagnates.com/forex/regulation/fca-cuts-108-million-a-year-from-reporting-costs-but-keeps-cfds-in-scope/); [Charltons](https://charltonsquantum.com/fca-ps26-15-transaction-reporting-reform/)). ## What stays the same - **CFDs remain in scope.** A broker offering CFDs to UK clients keeps a transaction reporting obligation for them ([Finance Magnates](https://www.financemagnates.com/forex/regulation/fca-cuts-108-million-a-year-from-reporting-costs-but-keeps-cfds-in-scope/)). - **Cryptoasset derivatives remain in scope** ([Charltons](https://charltonsquantum.com/fca-ps26-15-transaction-reporting-reform/)). - **UK EMIR reporting continues,** under the amended standards that applied from 26 January 2026 ([Bank of England](https://www.bankofengland.co.uk/paper/2025/ps/amendments-to-the-uk-emir-trade-repository-reporting-requirements-august-2025)). - **Data quality expectations do not drop.** Fewer fields do not mean less scrutiny of the ones that remain. ## Who is affected - UK investment firms that execute transactions in reportable instruments, including CFD brokers - Firms trading FX derivatives, which move out of transaction reporting - Approved reporting mechanisms, reporting vendors and in-house reporting teams, who rebuild mappings to the new schema - Liquidity providers that report on behalf of brokers under delegated arrangements ## What brokers should do now 1. **Map your instruments.** List which products you report today under MiFIR and which of them are FX derivatives that leave scope. Keep CFDs and crypto derivatives in. 2. **Confirm the FX route under UK EMIR.** Make sure FX derivative trades are complete and accurate in your UK EMIR reports before you stop reporting them under MiFIR. 3. **Get the draft schema in front of whoever builds your reports,** in-house or vendor, and agree a test plan well before April 2028. 4. **Re-plan corrections.** With a three-year back-reporting window, review how far back your current remediation work goes. 5. **Decide whether to move early,** given the FCA's flexible approach from 3 August 2026, and document the decision. 6. **Ask your reporting provider for a written PS26/15 plan,** with dates. ## Open questions - **Is the FX exemption absolute or conditional?** Most coverage describes a full removal of FX derivatives from MiFIR scope. KPMG describes them as exempt where equivalent reporting exists under UK EMIR ([KPMG](https://kpmg.com/in/en/insights/2026/10/fca-transaction-reporting-update-key-changes-in-ps26-15.html)). Read paragraph-level wording in the policy statement before relying on either reading. - **How many firms are affected?** Summaries of the FCA's announcement cite roughly 400 UK firms for the FX change. Confirm in the policy statement. - **Has the final schema been published?** Draft schema and validation rules were slated for October 2026. Check the FCA's transaction reporting pages for the current version. ## For vendors selling into brokers PS26/15 is a sales calendar with a fixed end date. Between now and April 2028 every UK CFD broker will ask the same questions: what leaves scope, what stays, who rebuilds the reports, and when to test. If you sell reporting, data quality, surveillance or liquidity with delegated reporting, the vendors that answer those questions in public first will be on the shortlist. What that looks like in practice: an explainer like this one on your own site, a migration checklist, a page comparing in-house, delegated and vendor reporting, and an AI facts page that says clearly which regimes you support. [How we build these pages for vendors](https://roteiro.consulting/services/comparison-page-engine) ## FAQ **Do CFD brokers still have to transaction report under PS26/15?** Yes. CFDs stay in scope of UK transaction reporting. What changes for CFD brokers is the schema, with 52 fields instead of 65, the three-year back-reporting window, and the removal of FX derivatives, which are covered through UK EMIR instead. **When does PS26/15 apply?** The new regime applies from 3 April 2028. The FCA published the policy statement on 3 August 2026 and applies a flexible supervisory approach to firms that move early. Plan testing around the final schema, which was expected in draft in October 2026. **Are FX derivatives still reported anywhere?** Yes, under UK EMIR. The FCA's reasoning is that EMIR data is the better source for FX derivatives. Check whether your firm relies on any condition attached to the exemption, because commentators describe it differently. **Does this change UK EMIR reporting?** Not directly. UK EMIR reporting continues under the amended technical standards that applied from 26 January 2026. PS26/15 changes MiFIR transaction reporting. ## Sources 1. FCA, PS26/15 Improving the UK transaction reporting regime. https://www.fca.org.uk/publications/policy-statements/ps26-15-improving-uk-transaction-reporting-regime (primary; not reachable from the build session, check before publishing) 2. CMS, "FCA: PS26/15: Improving the UK transaction reporting regime". https://cms.law/en/gbr/regulatory-news/fca-ps26-15-improving-the-uk-transaction-reporting-regime 3. HLC, "The UK streamlines transaction reporting requirements". https://hlc.com/en/publications/the-uk-streamlines-transaction-reporting-requirements 4. KPMG, "FCA transaction reporting update: Key changes in PS26/15", October 2026. https://kpmg.com/in/en/insights/2026/10/fca-transaction-reporting-update-key-changes-in-ps26-15.html and PDF https://assets.kpmg.com/content/dam/kpmgsites/in/pdf/2026/10/fca-transaction-reporting-update-key-changes-in-ps26-15.pdf 5. Finance Magnates, "FCA cuts £108 million a year from reporting costs but keeps CFDs in scope". https://www.financemagnates.com/forex/regulation/fca-cuts-108-million-a-year-from-reporting-costs-but-keeps-cfds-in-scope/ 6. Charltons Quantum, "UK FCA finalises transaction reporting reform in PS26/15". https://charltonsquantum.com/fca-ps26-15-transaction-reporting-reform/ 7. The Industry Spread, "FCA drops FX derivatives from UK transaction reporting by 2028". https://theindustryspread.com/fca-fx-derivatives-uk-transaction-reporting-2028/ 8. FX News Group, "FCA to remove FX derivatives from scope of transaction reporting regime". https://fxnewsgroup.com/forex-news/regulatory/fca-to-remove-fx-derivatives-from-scope-of-transaction-reporting-regime/ 9. Bank of England, "Amendments to the UK EMIR Trade Repository reporting requirements", August 2025. https://www.bankofengland.co.uk/paper/2025/ps/amendments-to-the-uk-emir-trade-repository-reporting-requirements-august-2025 All accessed 3 November 2026. Corrections: corrections@roteiro.consulting Source: https://roteiro.consulting/forex/regulation/fca-ps26-15-transaction-reporting (last verified 3 November 2026)