What is supervisory flexibility under FCA PS26/15?

Supervisory flexibility under FCA PS26/15 is a time-limited supervisory approach that allows firms to benefit from specified UK transaction reporting reforms before the new regime takes effect on 3 April 2028. It is not a general waiver of UK MiFIR transaction reporting requirements.

When did FCA PS26/15 supervisory flexibility take effect?

The FCA's implementation period and flexible supervisory approach began on 3 August 2026. The new transaction reporting regime itself is scheduled to take effect on 3 April 2028. The FCA also confirms these dates in its current PS26/15 guidance.

What transaction reporting changes can firms make now under PS26/15?

From 3 August 2026, specified changes include applying a three-year default back-reporting period, stopping reporting for certain instruments only tradeable on EU venues, stopping reporting certain FX derivatives already subject to UK EMIR reporting, and ceasing specified corporate-event reporting.

Can firms stop UK MiFIR transaction reporting under FCA supervisory flexibility?

No. Supervisory flexibility does not allow firms to stop submitting UK MiFIR transaction reports across the board. It applies only to specified areas and conditions, while requirements outside the scope of the FCA's flexible approach remain unchanged.

Which PS26/15 transaction reporting changes must wait until 2028?

Firms must wait until 3 April 2028 to use the new reporting schema and validation framework, comply with newly introduced mandatory fields and fully operate under the revised scope, content and technical rules.

Guides

Part 1 of 2 Supervisory Flexibility Explained: What Firms Can Change Now and What Must Wait

Published:24th September 2026

FCA supervisory flexibility does not suspend UK MiFIR transaction reporting requirements. PS26/15 provides a defined, time-limited supervisory approach for specified areas. It is not a general waiver of Article 26 transaction reporting obligations or permission for firms to stop reporting across the board.
From 3 August 2026, firms can apply the reduced three-year default back-reporting period and cease or simplify reporting in certain clearly identified areas, subject to the conditions in PS26/15.
Certain EU-only instruments and FX derivatives can fall within the immediate relief. The guide explains that firms may stop reporting instruments that are only tradeable on EU trading venues and FX derivatives where the firm is subject to UK EMIR reporting for the same transactions.
Some changes require firms to check technical validation readiness first. Existing validation rules may still cause reports to reject. Firms should coordinate changes with their ARM, vendor or direct-reporting solution before they stop populating fields that remain technically mandatory.
The new reporting framework does not go live until 3 April 2028. The new reporting schema, validation framework, newly introduced fields and full revised scope, content and technical requirements must wait until the new regime goes live.

The FCA’s PS26/15 introduces significant changes to the UK transaction reporting regime, but not every change takes effect at the same time. Some supervisory flexibility has been available since 3 August 2026, while other changes depend on validation updates or must wait until the new regime takes effect on 3 April 2028.

Part 1 of our two-part Supervisory Flexibility Guide explains what firms can change now, what must wait and where technical constraints may affect implementation. Read Part 2 for the practical suggestions on how to prepare for 3 April 2028, or download the complete guide for the full picture.

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Frequently asked questions

Supervisory flexibility under FCA PS26/15 is a time-limited supervisory approach that allows firms to benefit from specified UK transaction reporting reforms before the new regime takes effect on 3 April 2028. It is not a general waiver of UK MiFIR transaction reporting requirements.
The FCA's implementation period and flexible supervisory approach began on 3 August 2026. The new transaction reporting regime itself is scheduled to take effect on 3 April 2028. The FCA also confirms these dates in its current PS26/15 guidance.
From 3 August 2026, specified changes include applying a three-year default back-reporting period, stopping reporting for certain instruments only tradeable on EU venues, stopping reporting certain FX derivatives already subject to UK EMIR reporting, and ceasing specified corporate-event reporting.
No. Supervisory flexibility does not allow firms to stop submitting UK MiFIR transaction reports across the board. It applies only to specified areas and conditions, while requirements outside the scope of the FCA's flexible approach remain unchanged.
Firms must wait until 3 April 2028 to use the new reporting schema and validation framework, comply with newly introduced mandatory fields and fully operate under the revised scope, content and technical rules.