Author: Matt Storey
08 May 2025
As highlighted in a recent SteelEye blog, MiFIR transaction reporting is undergoing significant changes in both the EU and UK. In that blog, we looked at the official documents - including EU legislation, ESMA papers, and UK FCA publications - needed to help you understand the evolving landscape.
Below, we've expanded on the topic and built out a timeline of the recent and upcoming changes associated with MiFIR transaction reporting. We also examine ESMA's past implementations performance, which will help provide context to understand what delays, if any, might be expected in this next rollout.
This is the second installment of a three-part blog series exploring the upcoming changes to MiFIR transaction reporting in the EU and UK. Stay tuned for the last blog in this series, where we'll cover the scope of the proposed changes, as well as how firms should respond.
Prefer to listen? Take this blog on the go with our AI-generated podcast by listening here.
To help track the rollout of these changes, below is a timeline of key milestones in the EU and UK relating to MiFIR transaction reporting reforms in 2024–2025. The timeline highlights regulatory events, consultation periods, and expected implementation dates.
The timeline below focuses on 2024–2025 milestones. Beyond 2025, EU firms should anticipate compliance with the new RTS 22 requirements (likely in 2026 after a technical implementation period), while UK firms should be prepared for new FCA rules coming into effect once the UK’s consultation and rulemaking process is complete (potentially in 2026). Firms operating in both jurisdictions will need to track both schedules.
Date |
EU - MiFIR Transaction Reporting Developments |
UK – MiFIR Transaction Reporting Developments |
Mar-21 |
|
|
28 Mar 24 |
|
|
3 Oct 24 |
|
|
7 Nov 24 |
|
|
14 Nov 24 |
|
|
15 Nov 24 |
|
|
17 Jan 25 |
|
|
14 Feb 25 |
|
|
Q1-25 |
|
|
H2-25 |
|
|
Although past performance is no guarantee of future results, it provides helpful context to understand ESMA’s delays in implementing such regimes historically. This breakdown may provide a degree of comfort to the affected teams that will be tasked with supporting these new requirements.
Regulatory Output (Framework) |
Expected Timeline |
Actual Publication/Delivery |
Delay |
MiFIR RTS 22 – Transaction Reporting (MiFID II/MiFIR) |
Expected to apply from 3 Jan 2017 (MiFID II original go-live) |
In force on 3 Jan 2018 (final RTS in Commission Delegated Reg. 2017/590) |
12-month delay |
MiFIR RTS 23 – Reference Data (MiFID II/MiFIR) |
Expected to apply from 3 Jan 2017 (MiFID II original go-live) |
In force on 3 Jan 2018 (final RTS in Commission Delegated Reg. 2017/585) |
12-month delay |
EMIR Margin RTS – Final phase of Initial Margin for non-cleared derivatives (EMIR) |
All covered counterparties initially to exchange margin by 1 Sep 2020 (original final phase-in deadline) |
Final phase took effect 1 Sep 2022 after two one-year extensions (smallest counterparties delayed) |
24-month delay |
EMIR Refit Reporting Standards – Revised RTS/ITS for trade reporting (EMIR) |
ESMA mandated to deliver draft standards by 18 Jun 2020 (per EMIR Refit Regulation) |
ESMA’s final report submitted late 2020; EU adopted final rules in 2022 (reporting start April 2024) – effectively ~6 months behind initial schedule |
~6-month delay |
SFTR Reporting Go-Live (Phase 1) – Trade reporting for banks (SFTR) |
Initially scheduled for 13 Apr 2020 (first wave of SFTR reporting go-live) |
Actually went live on 13 Jul 2020 after ESMA’s COVID-19 deferral (NCAs applied 3-month forbearance on enforcement) |
3-month delay |
MAR Review Report – ESMA’s technical advice on Market Abuse Regulation |
EU Commission’s review report was due by 3 Jul 2019 (MAR Article 38 mandate) – implying ESMA’s input expected by mid-2019 |
ESMA delivered its MAR review report on 24 Sep 2020, with proposals to amend MAR (Commission report published subsequently) |
~14-month delay |
If you’re interested in streamlined compliance and future-proof transaction reporting solutions, we invite you to:
Book a Demo and see our platform, where we’ll walk you through how our end-to-end MiFIR reporting solution helps automate data capture, validate field requirements, and monitor compliance under both EU and UK regimes.
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We look forward to supporting you through these changes!
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