RegEdge Insights: Navigating Trade & Transaction Reporting

Blog Series on Regulatory Developments, Challenges, and Best Practices

Welcome to the RegEdge Trade & Transaction Reporting Blog Series, where we delve into key regulatory developments, enforcement trends, and best practices across MiFID, EMIR, SFTR, and other global reporting frameworks. Our goal is to provide practical insights to help firms navigate complexities, avoid regulatory pitfalls, and enhance reporting controls.

FCA’s First UK MiFIR Fine: A Sign of Increased Scrutiny?

On January 29, 2025, the FCA issued its inaugural fine under UK MiFIR—a £99,200 penalty for under-reporting 46,053 transaction reports. Although modest compared to previous fines, this enforcement suggests that regulators are actively identifying data quality issues—and firms should take notice.

How Are Regulators Detecting Reporting Failures?

The under-reporting was not self-identified but was detected by the FCA, likely through routine data reconciliation and quality checks. Transaction reporting should offer a complete and consistent narrative—when one counterparty reports a trade but the other doesn’t, discrepancies become apparent.

With the introduction of ISO 20022 and upcoming EMIR 3.0 changes, regulators will have even greater visibility into reporting inconsistencies. Under EMIR 3.0, firms may face fines of up to 1% of average daily turnover per day for systematic errors.

Regulatory Reporting Fines: A Look Back

The FCA and other regulators have historically imposed fines for transaction reporting failures. Please see snippet below:

• 2024 – €90,000 fine on a Pension Provider from the Finnish Financial Supervisory Authority (FIN-FSA) for failures in EMIR derivative contract reporting. Between 2019 and 2023, reporting obligations were not met due to the absence of delegation agreements with four counterparty banks, leading to unreported transactions. 

• 2023 – €192,500 fine on an Investment Fund from the Central Bank of Ireland for failure to report 200,640 derivative trades under EMIR between January 2018 and May 2020. The breach stemmed from gaps in oversight and delegation of reporting responsibilities, delaying issue identification and regulatory notification.

• 2023 – €186,000 fine on a trade repository from ESMA for eight breaches of the European Market Infrastructure Regulation (EMIR) between 2017 and 2020. The breaches were due to failures in ensuring data integrity and providing direct access to regulators, including incorrect rejections of properly reported data, generating faulty reports, and missing reporting deadlines.

  
  

These fines highlight that transaction reporting issues remain a regulatory focus, with firms and Trade Repositories being held accountable for both under-reporting and over-reporting errors.

For more information on FCA fines over the years please see here. For more information on ESMA sanctions and fines please see here.

What Should Firms Be Doing Now?

In light of the latest FCA action, firms should proactively:

✅ Strengthen data quality controls—Ensure transaction reports align across counterparties and are free from systematic errors.

✅ Enhance governance and oversight—Establish robust escalation processes to address reporting gaps.

✅ Prepare for EMIR 3.0 & ISO 20022—Assess system readiness for upcoming regulatory changes.

Coming Up Next in Our Blog Series

Over the next few weeks, we’ll be covering:

• EMIR 3.0 – What Firms Need to Do Now to Prepare for the Upcoming Changes

• MAS & HKMA Reporting Challenges – Key Differences from US & EU Frameworks

• ISO 20022 – The Next Phase of Transaction Reporting Standardization & Its Impact on Firms

• CFTC & SEC: US Derivatives & Securities Reporting Trends for 2025

How RegEdge Can Help

RegEdge collaborates with broker-dealers, hedge funds, investment banks, and crypto exchanges to enhance their regulatory reporting frameworks. Our team of former regulators, industry SMEs, and ex-Big 4 consultants assists firms in:

✔ Assessing and remediating reporting issues before they lead to regulatory fines

✔ Implementing scalable transaction reporting controls that meet global regulatory expectations

✔ Preparing for EMIR 3.0, MiFID III, and ISO 20022 changes with tailored impact assessments

If you’d like to discuss your firm’s reporting challenges, get in touch with us. https://www.regedge.com/all-services