What is the FCA proposing in CP25/32?

CP25/32 proposes a major rewrite of the UK transaction reporting regime, representing the most significant overhaul since the current framework was introduced in 2018.

How much savings does the FCA predict from the UK MiFID rewrite?

The FCA estimates the changes could reduce firms’ annual transaction reporting costs by around 25% once the new framework is fully implemented.

What did the Qomply industry poll reveal about the FCA’s savings estimate?

Following a Qomply webinar with over 250 buy-side and sell-side professionals, the poll indicated the industry is cautious about the FCA’s projected savings and not ready to rely on the 25% figure yet.

How many firms expect savings to be lower than 25%?

In the poll, 22% of respondents predicted that savings would be lower than the FCA’s 25% estimate.

Why are firms skeptical about the FCA’s predicted savings?

Many firms expect a significant “cost of change,” including upfront investment to untangle legacy systems, update controls, and implement new reporting logic before any long-term savings are realised.

What is the biggest implementation challenge firms identified?

The poll suggests the biggest challenge is understanding and interpreting the new requirements—52% cited familiarisation with the new rules as their primary hurdle.

What technical and data challenges are firms expecting under CP25/32?

Respondents highlighted data lineage and new schemas (32%) and the development of new processes (32%) as key challenges, reflecting the need to map, source, and govern additional or revised data fields.

What costs do firms expect to be highest during implementation?

The poll indicates IT costs and upgrades are expected to be the biggest implementation expense, with 74% of respondents identifying technology change as the largest cost driver.

How does the Conditional Single-Sided Reporting Model affect firms?

The model introduces additional operational complexity by changing how responsibility for reporting may be determined in specific scenarios, requiring firms to interpret the rules and implement logic that is accurate, consistent, and auditable.

How can firms prepare for the UK MiFID rewrite?

Firms can prepare by building internal understanding of CP25/32, assessing impacted data fields and workflows, strengthening data lineage, and planning IT changes early to reduce implementation risk and avoid late-stage surprises.

When are the final revisions to the UK MiFID framework expected?

The final revisions are expected later this year, after the FCA completes the consultation process and formalises the requirements.

How will Qomply support clients through the transition?

Qomply plans to support clients by providing a dedicated UAT environment, proactively highlighting fields likely to change, and sharing insight on new rules so firms can identify gaps and plan enhancements ahead of switchover.

The UK MiFID Rewrite: FCA Predicts Savings. Industry Remains Skeptical

Author: Michelle Zak

Managing Director
23 February 2026

The FCA’s proposed UK MiFID rewrite promises material cost savings and a streamlined reporting framework. However, industry sentiment suggests a more cautious outlook. Drawing on market feedback and regulatory analysis, this article explores the differences between projected efficiencies and practical implementation challenges.

The Financial Conduct Authority’s (FCA) Consultation Paper (CP25/32) proposes the most significant overhaul of the UK transaction reporting regime since its introduction in 2018.

By its own account, the FCA is predicting that these changes will ultimately save the industry around one-quarter (25%) of firms’ current annual transaction reporting costs.

However, a recent industry poll conducted by Qomply suggests the market is hesitant to bank on these savings just yet.

Qomply polled over 250 industry practitioners, across the buyside and sellside, and the data reveals a stark gap between regulatory intent and operational reality.

The Verdict: “Too Early to Tell”

Despite the FCA’s estimate, the industry is cautious. When asked if they anticipated savings around 25%,

58% of respondents stated it was “too early to tell” or were unsure.
Only 3% believed savings would be higher than 25%.
22% actually predicted savings would be lower than the regulator’s estimate.

This scepticism likely stems from the “cost of change.” While the end state, reporting on fewer instruments, is leaner, the transition requires significant upfront investments to untangle legacy systems.

Question: The FCA estimates that the proposed measures in CP25/32 could deliver cost savings equivalent to around one-quarter of firms’ current annual transaction reporting costs.
Do you think the actual savings for your organisation will be…

The Knowledge Gap is the Primary Challenge

The poll identified that the single biggest hurdle for implementation is not technology, but interpretation of the potential guidelines.

52% of respondents cited “Familiarisation with the new requirements” as their biggest challenge.
This was followed by “data lineage/New schemas” (32%) and “Development of new processes” (32%).

This signals a need for subject matter expertise. CP25/32 introduces significant complexity, including the new Conditional Single-Sided Reporting Model and a battery of additional data fields. Many of these fields may require changes to IT systems, and their interpretation requires regulatory analysis before implementation can begin.

Question: What is the biggest challenge you expect to face in implementing the new regime? (Multiple choice)

IT and Data Lineage: The Hidden Costs

Once the rules are understood, the focus shifts to execution. A massive 74% of respondents identified IT costs/upgrades as their biggest expected implemented cost.

This aligns with the need for what Qomply calls “Operational Intelligence.” Firms are realising that adapting to the UK MiFID rewrite will require more than just updating fields.

Question: What do you feel the biggest implementation costs will be? (Multiple choice)

The Bottom Line

The UK MiFID rewrite offers a potential path to savings on transaction reporting, but the path remains unclear and complex. As the poll results indicate, the majority of firms are waiting for more clarity before they accept the regulator’s savings projection as fact.

The final revisions to MiFID are expected later this year. Once the FCA formalises the requirements, Qomply will work closely with clients to support a smooth transition. In addition to providing a dedicated UAT environment, we will proactively highlight the data fields that are expected to change as well as new rules that will highlight upcoming changes that may be required in their reporting.

This approach is designed to give firms early visibility of potential gaps within their current MiFID reporting and a clear understanding of the enhancements that may be required ahead of the switchover. By sharing insight as the framework develops, we aim to help clients prepare in a structured and informed way.

UK MiFID Rewrite: FCA Savings, Industry Skepticism

Key Takeaways

The FCA expects cost savings from the UK MiFID rewrite, but many firms remain skeptical about the scale and timing of those efficiencies.
Implementation complexity is being underestimated, particularly around data sourcing, mapping logic and systems changes.
Knowledge gaps pose a material risk, with many firms unsure how the new framework will affect their reporting controls.
Governance and quality assurance will be critical to avoid post-implementation remediation and regulatory scrutiny.
Early preparation reduces risk, especially where trade capture, reconciliation and backreporting processes may require redesign.

The UK MiFID Rewrite

FCA Predicts Savings. Industry Remains Skeptical.

Key Takeaways

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