The FCA's new transaction reporting regime: what it means for your LEI

The FCA has finished rewriting the UK transaction reporting regime. Its policy statement PS26/15, published on 3 August 2026, sets out the final rules, and the follow-up consultation CP26/34 is open for comments until 6 November 2026. The new regime applies from 3 April 2028.

Most of the changes are aimed at investment firms and their reporting teams. But one thing has not changed: if your company buys or sells shares, bonds or derivatives through a UK broker, the LEI is still the key that lets the trade happen.

What is changing?

The FCA says the reforms will cut industry reporting costs from about £493 million to £385 million a year. The main changes are:

• Fewer fields: a transaction report drops from 65 to 52 fields.
• Narrower scope: only instruments that can be traded on UK trading venues remain reportable. According to the FCA, around 7 million EU-only instruments fall out of scope.
• FX derivatives removed: currency forwards, swaps, options and futures leave the regime, because the same trades are already reported under UK EMIR.
• Shorter back-reporting: firms correcting past errors now go back three years instead of five, with effect from 3 August 2026.
• New rulebook: the requirements move into new chapters of the FCA Handbook (MAR 14 and MAR 15), supported by a new Transaction Reporting User Pack, due in final form by 3 April 2027.

What stays the same for LEI holders

The core LEI rule survives. PS26/15 restates that transaction reporting firms must obtain an LEI from clients that are eligible for one before providing a service. In practice, this is the familiar "no LEI, no trade" rule that has applied since MiFIR came into force in 2018.

So for a UK company, holding company, pension scheme, charity or fund that invests, nothing in the new regime removes the need for an LEI. What matters is that the LEI is valid and that its data is correct when your broker checks it.

Three LEI details worth knowing

1. Trusts must use their LEI if they have one. Until now, trusts had to be identified with an LEI in almost all cases. Under the new rules, firms report the trust's LEI where one already exists, and only fall back to identifying the beneficiaries where there is no LEI. If your trust already holds an LEI, keep it renewed: it is now the identifier your broker is expected to use.

2. Unknown counterparties are reported with the CCP's LEI. When a trade on a venue is executed without knowing the counterparty, firms report the LEI of the central counterparty. This codifies existing practice and shows how central the LEI remains to the regime.

3. "Retired" issuer LEIs are accepted in reference data. For instrument reference data, a retired LEI will be a valid status for the issuer, which should reduce rejected submissions when an issuer has been merged or dissolved.

Why a lapsed LEI is still a problem

An LEI must be renewed every year. When it isn't, its status changes to "lapsed" in the GLEIF database. Globally, only around 57% of LEIs were renewed on time in Q3 2026, and the rate outside the EU was lower still, according to GLEIF's latest figures.

Brokers check LEI status as part of their reporting controls, and many will not execute trades for a client whose LEI has lapsed. A lapsed LEI also means your reference data has not been re-validated, so changes such as a new registered office or company name may not be reflected.

What should UK companies do now?

• Check your LEI status in the GLEIF database or with your LEI provider.
• Make sure the reference data matches Companies House, including your legal name and registered office address.
• Turn on automatic renewal so your LEI never lapses between trades.
• If you hold investments through a trust, check whether the trust has its own LEI and keep it current.

The new transaction reporting regime is a big project for investment firms, but for LEI holders the message is simple: keep your LEI valid and accurate, and your broker can keep trading for you.

At Global FinReg, you can register, renew or transfer your LEI online, and renewals can be set to run automatically.