The regulator is reportedly deliberating on a number of changes to the present framework, and MAP FinTech is prepared to provide a thorough response to the FCA's survey.

While not all of the FCA's suggested changes are detailed, they do represent a move in the right direction, albeit one that is less drastic than what the European Securities and Markets Authority (ESMA) may suggest. The possible addition of new data fields to the reporting specifications is one example of this.

Importantly, the FCA intends to include UCITS Management Companies and Alternative Investment Fund Managers (AIFMs) in the MiFIR reporting requirements. If these organizations offer non-core services like investment advising, discretionary portfolio management, or the administration and safekeeping of shares or units in collective investment endeavors, they will be required to disclose transactions.

The incorporation of a Universal Product Identifier (UPI) for securities under UK MiFIR Articles 26(2)(b) is another noteworthy suggestion. To better meet the unique requirements of the UK market, the FCA is considering adopting both a normal UPI and a customized version called UPI+.

Furthermore, for Distributed Ledger Technology (DLT) securities and financial instruments backed by crypto-assets, the FCA wants to implement the ISO 24165 Digital Token Identifier. This action would conform to international standards such as the DTIF codes for derivatives on crypto assets and make it easier to identify tokenized securities.

In order to classify clients or counterparties as either "Retail Client" or "Professional," the consultation paper also recommends adding a new field to transaction reports. Clearer information about the characteristics of each trade's counterparty will be made possible by this categorization.

Additionally, the FCA is looking into methods to lessen reporting requirements, particularly for smaller businesses that find compliance difficult and expensive. Since the criteria of MiFIR frequently overlap with those of other reporting frameworks, including EMIR, they are looking for input on how to remove duplication.

Finally, in an effort to improve the effectiveness of transaction reporting, the FCA is soliciting input on the application of new technologies and alternative communications formats, such as JSON. In order to improve and streamline the reporting procedure in response to industry demands, the authority is accepting proposals until February 14, 2025.