On 31 July 2026 the Financial Conduct Authority (FCA) published a package on transparency in equity trading. It settles what a consolidated tape for UK shares will look like, puts two points out to consultation and switches on a free interim tool. For any firm running a trading book in London, this is not a regulatory footnote. It determines the data on which that firm demonstrates the quality of its executions.

A consolidated tape gathers trading data from every venue in a market into a single stream. The United States has had one since the 1970s. Europe still has none, and that is precisely what Brussels and London are now building in parallel.

At a glance

What: the framework for a UK equity consolidated tape, two consultations and a free interim tool

Who: the Financial Conduct Authority, published on 31 July 2026

Settled: the tape carries post-trade data and the best pre-trade quote, and that quote is attributed to its venue

Open: whether systematic internaliser quotes are included, closing 16 October 2026

Timing: procurement of a provider from early 2027, operations in 2027 or early 2028 per the regulator

Contested: the London Stock Exchange is publicly resisting pre-trade data in the tape

Why a tape at all

UK equity trading has been draining out of the central order book for years. The regulator documented that shift in its consultation paper CP25/31, drawing on data from the analytics firm big-xyt. Between January 2018 and May 2025 the share of the central limit order book (CLOB) fell from 47 to 29 per cent. Bilateral trading rose from 31 to 40 per cent over the same period, off-exchange trading through systematic internalisers from 15 to 19 per cent, other off-exchange trading from 4 to 10 per cent. Periodic auctions grew from half a per cent to five.

This is not a marginal drift. It is the halving of the share held by the one venue where price formation happens in public. Read the price of a UK share off the primary exchange today and you are looking at a shrinking slice of the market.

The regulator itself has now quantified just how small that slice is. The Market Activity Reporter for shares, free to use since 31 July, publishes the number, volume and value of transactions for each share on each trading day, both as total activity and adjusted for technical trades. The series runs back a full year to 1 August 2025. The regulator states that the value of UK share trading addressable by market participants runs consistently around three times higher than data from the primary exchange alone would indicate.

For anyone on a desk, that is the real news of the day. Two thirds of the addressable market never appeared in the statistics against which execution quality was being measured.

What the regulator has settled

The package has three parts. The framework for the equity tape is now final. That document carries the reference CP26/31 and, despite a title that opens with the words Policy Statement, is formally a consultation paper. Across 273 pages it sets out binding rules that took effect on the day of publication, together with a consultation chapter and a call for input. Alongside it, CP26/30 puts a set of market structure proposals out for comment. And the Market Activity Reporter goes live.

On substance, the decisive choice is that the tape carries more than post-trade data. It also carries the first layer of pre-trade data, meaning the best bid and offer. Depth stays out; the tape stops at the top of the book. Anyone who needs more will go on buying feeds from individual venues.

A second decision has drawn less attention and will cost more. The future operator must share part of its revenue with the firms that supply the data. That point was left open in the original proposal. Venues and publication service providers, in turn, are obliged to deliver data to the operator once it has been appointed. How the money is split will be consulted on separately in autumn 2026.

The market structure proposals in CP26/30 run in a direction that may surprise some readers. The regulator proposes no attempt to steer trading back towards central order books. It states plainly that current evidence does not justify prescriptive intervention to push trading towards particular execution mechanisms. What it proposes instead is a monitoring framework tracking market share, spreads, depth, volatility and execution quality on an ongoing basis. Intervention options are discussed, but as contingencies should conditions deteriorate, not as proposals on the table today. The systematic internaliser regime, by contrast, tightens: those firms would have to publish quotes carrying both price and volume up to standard market size.

The difference that matters on the desk

The obvious reading of this announcement is that London is catching up on transparency. That reading fails, and it fails in both directions.

On equities the European Union genuinely is ahead. The European Securities and Markets Authority (ESMA) selected EuroCTP on 19 December 2025 and authorised it on 27 July 2026, four days before the British package appeared. The operator plans to start on 14 September 2026; the supervisory transition period runs to 30 September. The FCA, by contrast, only begins procuring its operator in early 2027 and gives 2027 or early 2028 as the point at which the tape starts running.

On bonds the picture reverses. The UK bond tape has been live since 22 June 2026, operated by ETS Connect UK. Ediphy, selected for the EU under the fairCT brand, has been working through authorisation since July 2025 with no confirmed start date. Which side leads therefore depends on the instrument. A blanket claim about who is faster does not survive contact with the evidence.

In any case the more consequential difference sits elsewhere, in a subordinate clause of CP25/31. The UK tape will attribute the best bid and offer to a specific venue. The European version of the Markets in Financial Instruments Regulation (MiFIR) requires the anonymous best bid and offer. The regulator adds that it is aware the EU is currently considering whether to amend the scope of its own equity tape.

In daily practice that is the line between a usable data product and a decorative one. A tape that shows the best price while withholding where it came from serves neither venue selection nor a best execution record. It tells you what was achievable without telling you where you should have routed. The British tape answers the second question; the European one, as currently framed, does not. Arriving later is not the same as arriving worse.

The fight that is still open

The sharpest opposition comes not from within the regulatory camp but from the country's largest exchange. Julia Hoggett, Chief Executive of the London Stock Exchange, argued against pre-trade data in the tape in a June 2026 post on the exchange's website. Her case is about free riding: a participant who wants to see everyone else's prices without contributing any of its own is shifting the burden onto everyone who does. She put it this way:

"It is a little like playing cards with someone who wants to see what everyone else is holding but keeps their own hand close to their chest."

And on the process itself: "It is also the case that introducing a damaging framework and assuming that any breakage to the system can be corrected afterwards may be playing fast and loose with market integrity."

One can explain this objection by pointing to the balance sheet, since the exchange group sells pre-trade data commercially and a publicly available tape erodes what that data is worth. The regulator acknowledged in CP25/31 that a pre-trade tape could produce a significant transfer of value. That observation, though, does not dispose of the argument. Duties to contribute that fall unevenly are a real economic problem, even when the party raising the objection stands to gain.

The regulator did not overrule the objection. It converted it into an open question. Whether systematic internaliser quotes appear separately in the tape is precisely the point now out for consultation until 16 October 2026. The decision has been deferred rather than taken. A second window closes earlier, on 18 September, covering the future operator's contractual terms: how revenue sharing will work in practice, and what hours the tape will run.

How much the timetable is worth

The package came with a commitment from Simon Walls, Executive Director of Markets at the FCA: "Today's package settles the big design questions and sets the path to deliver the tape within the next 18 months." Eighteen months from 31 July 2026 lands at the end of January 2028. That does not contradict the date on the regulator's own page. It describes the far end of it.

Whether that timeline holds can be estimated from the FCA's own precedent. Procurement for the bond tape opened in March 2025 and the contract was awarded in late summer. An unsuccessful bidder then challenged the award, the court lifted the automatic suspension only in December 2025, and the claim was withdrawn in May 2026. Roughly ten months passed between award and go-live, a substantial part of it litigation. A tender for the equity tape is open to the same challenge, and it has not yet started.

The other side is not delivering cleanly either. EuroCTP originally named July 2026 as its start date and has slipped to September. Its ownership raises a question of its own: the operator belongs to fifteen European exchange groups, the very firms whose data revenues a consolidated tape puts under pressure. That conflict is structural. The British route, a competitive tender with commercial terms fixed in advance, is the cleaner one on this dimension, even if it is the slower of the two.

What this means in practice

Four starting points for those responsible for trading, sales and market data.

1. Run the free reporter against your own view this week

Now: The tool costs nothing, gives number, volume and value per share per day, and reaches back a year. That is enough to establish, without a project and without a budget, how wide the gap really is between your own picture of the market and the addressable volume. Know that gap for your own names and every subsequent conversation about data costs rests on a figure rather than an impression.

2. Take a position on internaliser quotes before 16 October

By early October: Whether systematic internaliser quotes enter the tape is the only substantive question still open, and it is the one the country's largest venue is publicly contesting. Firms executing a meaningful share of their flow bilaterally are directly exposed. Skip the response and the field belongs to those who filed one. The same applies to 18 September for the operator's contractual terms.

3. Write attribution into your best execution reporting requirements

In planning: Whether the best quote is attributed or anonymous decides whether the tape can carry a record of execution quality or merely a sanity check. Firms trading into both regimes will work with two references of unequal evidential weight for a transitional period. That asymmetry belongs in the target architecture before any data contract is renewed.

4. Do not cancel existing data contracts in anticipation of the tape

Ongoing: The tape does not replace individual venue feeds. It carries the top of the book, not its depth, and latency-sensitive work will still need direct connections. Then there is the timing: on the regulator's own account, at least a year and an unstarted tender stand between today and a working UK tape. AFME, the industry association, also points out that a tape on its own does not resolve the question of market data costs.

Timeline: two tapes, two speeds
Who delivers on which instrument, and when
3 July 2025
EU selects its bond tape provider
Ediphy, trading as fairCT. Authorisation is still running and no start date is confirmed.
19 December 2025
EU selects its equity tape provider
EuroCTP, a joint venture of fifteen European exchange groups.
22 June 2026
UK bond tape starts operating
Operated by ETS Connect UK, roughly ten months after award and after a procurement dispute.
27 July 2026
ESMA authorises EuroCTP
Transition period to 30 September; the operator plans to start on 14 September.
31 July 2026
FCA settles the framework and opens two consultations
Attributed pre-trade quote, mandatory revenue sharing, free Market Activity Reporter.
18 September 2026
Deadline on contractual terms
Revenue sharing with data contributors and the operating hours of the future tape.
16 October 2026
Deadline for both consultations
Market structure, and the open question of systematic internaliser quotes.
Early 2027
Procurement of the UK equity tape operator begins
Operations in 2027 or early 2028 per the regulator; the promise says eighteen months.
Christian Schablitzki

Christian Schablitzki

Strategy & Management Consultant · Agentic AI expert for financial institutions

Over 20 years in investment banking and derivatives trading, followed by more than 10 years advising financial institutions. Currently a Partner at Infosys Consulting in Germany. Certified in Google AI, Generative AI Leader (Google Cloud) and IBM RAG and Agentic AI.

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