Under FCA Policy Statement PS24/14, the UK has recalibrated transparency requirements for bonds and derivatives. The new framework replaces a complex and often ineffective regime with a more targeted model based on ‘proportionate transparency’.

The most important structural change is a shift toward post-trade transparency. Executed trade data (price and volume) becomes the primary source of market insight, while pre-trade obligations—particularly for RFQ and voice-driven markets— are significantly reduced.

The regime also introduces simplified and more consistent rules, including streamlined deferrals for large trades, broader near real-time reporting across bonds and standardised OTC derivatives, and clearer categorisation of instruments based on liquidity.

More detail on product scope, size thresholds and deferrals can be found here (Page 43): PS24/14: Improving transparency for bond and derivatives markets.  

The transparency reforms are designed to enable the UK CT, which launches for bonds on 22 June 2026. The CT will provide a single, authoritative source of post-trade data by aggregating information from trading venues, OTC transactions and Approved Publication Arrangements (APAs). This will be delivered as a standardised, near real-time data feed covering prices and volumes.

Worth also thinking about how transparency and the CT impacts the derivatives market. The same concept of ‘post-trade transparency first, CT later’ applies:

• Dec-25 transparency reforms covered certain derivatives markets (including IRS subject to clearing) so we already have enhanced post-trade reporting  
• No published timeline (or scope) from the FCA yet for a CT
• In the EU the CT is planned (still being defined via RTS) but no firm go-live date

Improved price discovery and accessibility

• Historically, bond markets have been fragmented and opaque, with pricing information dispersed across multiple sources. The CT addresses this by creating a single view of trading activity, improving benchmarking, valuation and execution. 
• For clients, this reduces information asymmetry between market participants and enables more consistent and informed decision-making.
  
  

Liquidity: balancing transparency with depth

• The UK approach deliberately balances increased transparency with the need to preserve liquidity— particularly for large or sensitive trades.
• While greater transparency should support participation and confidence, safeguards such as deferrals and lighter requirements for less liquid instruments remain in place. This ensures the regime remains supportive of market-making and block liquidity provision.
  
  

Structural market shift

• The combined reforms and CT are expected to drive three structural changes: a move from fragmented to centralised data, increasing reliance on post-trade data for price formation, and a reduction in information asymmetry across market participants.
  
  

Market data and competition

• The CT is also likely to reshape market data economics by lowering access costs, reducing barriers to entry, and increasing competitive pressure on incumbent providers.

Globally, regulators are moving toward greater transparency and consolidated data, but with different approaches and timelines.

• The UK is pursuing a fast and pragmatic strategy, implementing simplified post-trade information reforms from December 2025 and launching a bond CT in June 2026 with a strong focus on usability and liquidity protection. 
• The EU is taking a broader but slower approach under the MiFID II/MiFIR review, introducing phased reforms through 2025–2026 and planning multiple consolidated tapes across asset classes. This reflects its priority of harmonising markets across member states.
• The US represents the most mature model, having long operated a bond consolidated tape through TRACE, providing centralised post-trade transparency. Enhancements continue, but the core framework is already well established.
   

It is worth noting that ~25% of UST are traded outside the US, therefore are likely captured by either UK or later EU CT. And a similar level of EU sovereign bonds trade on UK venues, thus being captured by UK CT. The subtle reporting difference between UK CT (volume and price) and US TRACE (price and direction but not volume) could drive participants selecting execution venues that minimize reporting footprint.

To bring this to life, consider the example of a mid-sized (€14m) 10Y OAT trade – this is reported in real-time in the EU, but deferred to 6pm T+1 in the UK, Participants seeking to minimise market footprint therefore may prefer to trade under the UK regime.

In a nutshell, transparency outcomes – and therefore, potentially market impact and ability to hedge - depend more on execution venue / dealer location than the underlying instrument.

Overall, while all three regions are converging toward greater transparency, the UK is leading on speed and implementation, the EU on cross-border harmonisation, and the US remains the most established operational model.