By Philip Buckingham, Compliance Director, UK and Feeras Juenda, Compliance Consulting Analyst
On 23 July 2025, the Financial Conduct Authority (FCA) published the 82nd edition of Market Watch, a periodic newsletter summarising the regulator’s supervisory observations in relation to the UK Markets in Financial Instruments Regulation (MiFIR) transaction reporting regime.
This edition of Market Watch will be of particular interest to firms subject to UK MiFIR transaction reporting requirements, as well as those subject to UK European Market Infrastructure Regulation REFIT (EMIR REFIT) and Securities Financing Transaction Regulation (SFTR) reporting requirements. Here, we summarise the key points addressed in the issue.
Transaction reporting
As the FCA notes, firms should have processes for identifying, addressing and disclosing regulatory reporting issues in a timely and accurate manner. In addition, these processes should have evolved and matured since the MiFIR transaction reporting requirements entered into force. However, the FCA has seen persistent shortcomings, suggesting that some firms must improve the operational frameworks governing their transaction reporting obligations (TRO) under MiFIR.
Remedial timelines
The FCA has set what it considers to be reasonable timeframes for the completion of remediation programmes, but has observed that some firms have been excessively dilatory in either establishing remediation programmes or completing them within internally or externally imposed deadlines.
The regulator has identified the following common themes that cause delays in completing remedial work:
- Internal processes: Siloed teams, fragmented ownership of tasks and lengthy approval chains slow down decision-making
- Resourcing: Assigning insufficient resource to resolve issues effectively and competing business priorities result in slower response times
- Difficulty in tackling the root cause: Focus on fixing the symptoms rather than the root cause leads to issues resurfacing
- Compliance culture: Reactive culture results in firms addressing issues only when prompted
- Governance: Weak structures and lack of accountability lead to loss of momentum as remedial work is not managed centrally or treated with urgency
Back reporting
The FCA distinguishes between protracted remediation of an issue and delayed back reporting as, according to the regulator, each presents a different set of operational and compliance risks.
Market Watch 82 sheds light on some of the common causes for delayed back reporting in four illustrative case studies:
Case study 1: Crystallised compliance risk
Case study 2: Internal governance weakness
Case study 3: Data access and infrastructure limitations
Case study 4: Impact on BAU
Breach notifications
In this Market Watch, the FCA emphasises the critical role breach notifications play in relation to data quality. In Q1 2025, the regulator received 241 breach notifications. Below, we summarise the FCA’s supervisory observations and best practices from its review of these notifications.
In summary, as part of a TRO breach notification, the regulator expects firms to:
- Provide a clear description of the issue identified
- Provide a clear account of the root cause(s)
- Provide the exact volume of transactions impacted
- Specify timelines for back reporting exercises
- Provide clear and relevant information on weaknesses in systems and controls and details of the firm’s plans to address this
- Provide details of the individual, working group, committee or other body with responsibility for oversight of the back reporting exercise
The FCA states that it will continue to monitor the quality of breach notifications closely and to that end has introduced a quality flag as part of its case management and record-keeping.
How we can help
Our experienced UK Compliance Consulting team at IQ-EQ can assist your firm with its reporting obligations under MiFIR transaction, EMIR REFIT trade repository and, where required, SFTR.
In view of the increasing scrutiny of the FCA on these topics, as highlighted by Market Watch 82, we can undertake health checks or quality assurance reviews to determine whether firms are complying with any or all aspects of their reporting obligations. Where shortcomings are identified that require remediation, we’re ready and willing to assist firms in whatever work streams are necessary to restore the firm to compliance.
Don’t hesitate to contact our UK Compliance Consulting team for an initial discussion to understand more about the assistance levels we can provide in respect of this high-profile regulatory risk topic.
