FCA Issues First UK MiFIR (RTS 22) Fine for Transaction Reporting Failures
Key Takeaways
- Transaction reporting accuracy and completeness are critical to the FCA’s ability to monitor market abuse.
- Weak systems, controls, and reconciliation processes can quickly lead to regulatory breaches.
- Firms are expected to identify and escalate reporting issues proactively, not wait for regulatory intervention.
- Even relatively small reporting gaps can result in enforcement action if they impact market oversight.
- The FCA is increasingly using data analytics to detect reporting failures, raising the likelihood of enforcement.
The FCA has issued its first UK MiFIR / RTS 22 enforcement fine for transaction reporting failures (£99,200), after a MiFID investment firm failed to submit over 46,000 reports—highlighting the regulator’s increasing reliance on data analytics, governance expectations and the importance of proactive self-reporting.
Key Points:
• Accurate Reporting is Crucial : Transaction reports are fundamental for regulatory oversight, helping detect and prevent market abuse.
• Systems & Controls Matter : The firm’s failure highlighted weaknesses in its reporting framework, data validation, and oversight mechanisms. This highlights the need for firms to have robust governance, automated reconciliation, and regular reviews to catch reporting gaps before regulators do.
• Proactive Notification is Key : While the firm eventually identified the issue internally, it failed to self-report to the FCA. Instead, the regulator uncovered the breach independently, an aggravating factor that breached Article 15(2) of RTS 22. Timely disclosure could have led to a more favourable outcome.
• The FCA is Watching : The regulator is increasingly relying on real-time data analytics and cross-market surveillance to detect non-compliance. This fine serves as a clear warning: if a firm isn’t reporting accurately, the FCA will find out.
This case marks the first-ever enforcement action for transaction reporting failures under UK MiFIR, setting a precedent for future cases. With regulators globally tightening their stance on data quality and transparency, firms must act now to ensure compliance.
At Qomply, our MiFID 101 as well as Governance training sessions cover the above points and are designed to equip firms with the tools to ensure reporting aligns with regulator expectations.
How Qomply can help
Qomply’s Regulatory Reporting Hub combines regulatory expertise with AI, automation and data analytics to deliver scalable, audit-ready reporting intelligence that reduces errors, lowers remediation costs, and minimises operational and regulatory risk.
Covering regimes including MiFIR, EMIR Refit, SFTR, CFTC, CSA, MAS, ASIC and HKMA, Qomply also offers a fully managed service and operates globally from London.
Frequently asked questions
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The FCA fined a MiFID investment firm £99,200 for failing to submit over 46,000 transaction reports, marking the first enforcement action under UK MiFIR RTS 22.
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The failure was driven by weaknesses in systems, controls, and oversight, including gaps in reconciliation and validation processes.
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Even though the number of missing reports was relatively small, the failure affected a high-risk product area and reduced the FCA’s ability to detect potential market abuse.
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No. The firm identified the issue internally but failed to notify the FCA promptly. The regulator detected the issue independently, which was considered an aggravating factor.
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