Benchmark your firm's readiness for the FCA's new transaction reporting regime before April 2028.
MiFIR transaction reporting transition checklist.
7 critical readiness areas | Self-scoring across ready / partial / attention | Banded into high, moderate, and early-stage readiness
Compliance officers, Heads of Compliance, and regulatory reporting leads at FCA-regulated investment firms are facing a significant transition. The FCA's revised UK MiFIR transaction reporting regime comes into force in April 2028, and the window to prepare is narrowing fast.
This self-assessment checklist provides a structured, practical framework to help your firm benchmark readiness across seven key areas: reporting inventory, reporting scope, governance and accountability, ARM and vendor readiness, reporting quality and remediation, policies and documentation, and transition planning. Drawing on deep regulatory insight from a team of former regulators and compliance professionals, the checklist equips you to identify gaps, prioritise remediation actions, and demonstrate control to the FCA.
Download the checklist to score your firm's current readiness, understand where attention is needed most, and access a clear roadmap to meet the April 2028 deadline with confidence.
Download the MiFIR transaction reporting transition checklist and benchmark your firm's readiness for April 2028.
This checklist is designed for compliance officers, Heads of Compliance, and regulatory reporting leads at FCA-regulated investment firms subject to UK MiFIR transaction reporting. It covers the seven critical areas your firm must address before the new regime comes into force in April 2028, and includes a self-scoring model to help you benchmark your current readiness. Inside, you'll find:
Reporting inventory
A structured review of your current transaction reporting inventory, including instrument coverage, reportable event identification, and alignment with the updated UK MiFIR reporting obligations taking effect in April 2028.
Reporting scope
Assessment of whether your firm has correctly identified all in-scope instruments, counterparties, and transaction types under the revised UK MiFIR regime, including any changes to scope boundaries introduced by the new rules.
Governance and accountability
Evaluation of your firm's governance structures and accountability arrangements for transaction reporting, including Senior Manager ownership, oversight mechanisms, and escalation processes for reporting failures.
ARM and vendor readiness
Review of your Approved Reporting Mechanism and third-party vendor arrangements, including contractual readiness, system upgrade timelines, and vendor confirmation of compliance with the new technical standards.
Reporting quality and remediation
Assessment of your existing data quality controls, error detection processes, and remediation capability, including your firm's approach to identifying and correcting historic reporting errors ahead of the new regime.
Policies and documentation
Review of your transaction reporting policies, procedures, and internal controls documentation to confirm they reflect the updated UK MiFIR requirements and are sufficiently detailed to support consistent, accurate reporting.
Transition planning
Evaluation of your firm's transition plan for the April 2028 implementation date, including project governance, milestone tracking, resource allocation, testing schedules, and Board-level oversight of the transition programme.
Ready to benchmark your MiFIR transaction reporting readiness?
Download the MiFIR Transaction Reporting Transition Checklist and benchmark your firm's readiness across the seven key areas ahead of the FCA's new regime coming into force in April 2028. Compiled by fscom's regulatory reporting specialists, this self-assessment tool helps compliance officers and operations leads at FCA-regulated investment firms identify gaps, prioritise actions, and demonstrate preparedness to senior stakeholders.
What does the MiFIR transaction reporting transition checklist cover?
The checklist covers seven key areas of MiFIR transaction reporting readiness: reporting inventory, reporting scope, governance and accountability, ARM and vendor readiness, reporting quality and remediation, policies and documentation, and transition planning. Each area is assessed using a self-scoring model to help your firm identify where it stands ahead of the April 2028 regime.
Who produced this checklist?
The checklist has been developed by fscom's Compliance Maturity Specialists™, drawing on deep expertise in UK MiFIR transaction reporting, FCA regulatory expectations, and hands-on experience supporting FCA-regulated investment firms through reporting reviews and remediation programmes.
Who should use this checklist?
This checklist is designed for compliance officers, Heads of Compliance, and operations or regulatory reporting leads at FCA-regulated investment firms currently subject to UK MiFIR transaction reporting obligations. If you are responsible for ensuring your firm's reporting framework is ready for the changes coming into force in April 2028, this tool provides a structured, practical starting point.
How does the self-scoring model work?
The checklist includes a self-scoring model across all seven readiness areas, with each area rated as ready, partial, or attention required. Your scores are then banded into an overall readiness rating, high, moderate, or early-stage, giving you a clear, actionable picture of where your firm's transition programme stands today.
How will this checklist help my firm prepare for the April 2028 changes?
The checklist helps you benchmark your firm's current readiness against the seven areas most critical to a successful MiFIR transition, identify specific gaps in your reporting framework, governance, vendor arrangements, and documentation, and prioritise remediation activity with sufficient time ahead of the April 2028 deadline.
Can fscom provide additional support with our MiFIR transition?
Yes. If your checklist results highlight gaps or you would like tailored support with your MiFIR transition programme — including reporting reviews, ARM and vendor readiness assessments, or governance and policy development — contact fscom at info@fscom.co.
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Your MiFIR transaction reporting readiness, measured, mastered, maximised.
If your self-assessment has identified gaps in your firm's MiFIR transaction reporting readiness, fscom's specialists can help. From reporting inventory reviews and ARM vendor assessments to governance frameworks and remediation planning, we provide practical, expert-led support to strengthen your position ahead of the April 2028 regime change.
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About the MiFIR transaction reporting transition checklist
fscom's Compliance Maturity Specialists help FCA-regulated investment firms measure, master, and maximise their transaction reporting frameworks. We benchmark where firms stand today against current and incoming regulatory requirements - and provide practical, actionable guidance to close gaps before they become enforcement risks.
The FCA's revised transaction reporting regime under UK MiFIR comes into force in April 2028. For compliance officers, heads of compliance, and regulatory reporting leads, the window to assess readiness and address weaknesses is now. This self-assessment checklist covers seven critical areas - reporting inventory, reporting scope, governance and accountability, ARM and vendor readiness, reporting quality and remediation, policies and documentation, and transition planning. Each area is scored across a ready / partial / attention model, giving your firm a clear, banded readiness rating: high, moderate, or early-stage. Use it to identify where your programme is strong, where gaps exist, and where to focus effort ahead of the new regime.