Trade Reporting: Publications and Prints

In our Insights series, we have explored transparency and the changes since the FCA Transparency regime was updated on 1 December. However, to-date, we have not looked at the distribution of transaction reports - an area we are frequently asked about.

This week, we take a closer look at how reports are distributed throughout the day. Additionally, we also provide the year-on-year comparison for December and January, with regards to FCA Transparency.

The Distribution of Transaction Reports

We have recently received increased interest in when trades are reported, rather than the more typical questions around transaction count and volume. In Chart 1 below, we analyse the average number of transaction reports per hour for bonds traded on FCA venues (or reported by FCA-regulated APAs).

Looking at the bar chart, transaction volumes are reasonably consistent between 06:00 and 17:00 UTC (with a gradual upwards trend from 07:00 onwards). However, instead of gradually tailing off into the evening, we observe the largest spike of the day after 17:00. This might seem counter-intuitive, but it can be explained by the introduction of T+1 end-of-day reporting(which commenced on 1 December).

There is also a tail of around 500 trades still being reported between 19:00 and 21:00.

Reporting activity is present in every hour throughout the day, as MiFID reporting is mandatory not only for transactions on European trading venues, but also if a European entity is involved in the transaction.

Trading venues (as defined under MiFID) do not typically have fixed hours like a Regulated Market (e.g. a major stock exchange); therefore, electronic trading can occur at unusual times of the day. Additionally, Approved Reporting Arrangements (APAs), which receive and disseminate MiFID data to the public, often remain open far longer than traditional market hours.

It is also important to note that, as previously mentioned, the introduction of end-of-day reporting T+1 under the FCA regime has led to an increasing number of reports coming through around 18:00 UTC. However, this is set to increase further once the new ESMA regime goes live, as the end-of-day reporting can occur on T+0, T+1 or T+2 (depending on the type of bond and transaction details).

A Year-on-Year Comparison

So far in this series, we have compared the 2025 average deferral times before and after the FCA regime change. However, in Chart 2 below, we take a different approach by comparing December 2024 - January 2025 with December 2025 - January 2026. This gives us a true comparison across the same time period and highlights some interesting results.

The chart highlights that changes in real-time reporting are far more pronounced than may have been apparent in previous views. By stripping out all non real-time activity we can see a material increase in real-time reporting (i.e. under 1 minute) and a similar proportion reported within 15 minutes (it is likely the intent was to book this subset of trades immediately, but presumably they were delayed due to booking or system issues).

Less than three weeks remain until the new ESMA regime comes into effect and we will do a similar comparison once there is enough data to assess the impact across both regimes.