New transparency regimes in the EU and UK have been, according to regulators, a great success. At FILS Europe, regulators and market makers looked what still needs to change.
The FCA introduced its new transparency regime in December 2025, and ESMA in March.
READ MORE: FCA publishes new transparency requirements
Speaking at FILS Europe, Jon Relleen, director of infrastructure and exchanges at the FCA, stated that since the new regime was introduced, there has been a 70% increase in corporate bond reporting and a 30% increase in government bond reporting.
READ MORE: UK bond transparency jump outpaces EU, with reporting up 307%
According to the data, however, the picture is less rosy.
In a report from Bank of America, Propellant Digital data shows that as of May 2026 just 17% of sovereign bond volumes and 19% of corporate bond volumes were reported in real-time in the UK. In the latter’s case, this was a drastic decline from the 30% mark hit last December.
Around a quarter of corporate bond volumes are delayed by a day, while a further 29% are reported on a T+2 week basis. The remaining 29% is reported three months after the fact.
“Despite the huge percentage increases in real-time corporate bond volume reported in the UK, a minority of overall volume is reported in real-time,” BofA observed.
In the EU, just 13% of sovereign bonds were reported in real time in May – however, 28% of corporate bonds were reported in real time. A quarter are reported 15 minutes post-trade, 16% after a day, and 25% after a month.
“We have to balance the fact that we want as much real-time transparency as possible, but we also are mindful that intermediaries and dealers have to be protected to some extreme, particularly in stress,” Relleen said, explaining the limits of the current regime.
“I want to make it clear that we’re not done. We think it’s working really well, so we don’t want to make any major changes, just tweaks around the calibration so it can work even better,” he affirmed.
Stephen Berger, global head of government and regulatory policy at Citadel, agreed that the direction of travel was positive.
“I think we started at the right place but should keep in mind that we can realise further benefits from refining the deferral framework. When TRACE started, it had longer delays and a smaller universe of instrument coverage. Now, over 90% of trades are recorded within one minute.”
“Enhancing the transparency framework has the potential to improve outcomes for investors, narrow bid-ask spreads, and improve liquidity.”
READ MORE: Will credit transparency beget credit liquidity?
On the European side, ESMA was absent from the FILS discussion. Speaking on the relationship between the two regulators, Relleen commented, “In some cases the UK might be slightly ahead, in other cases vice versa. On a technical level, we have a really good relationship with ESMA. We compare notes, and we see that we are getting similar feedback.”
“Sometimes the regulatory backdrop is slightly different, the markets are slightly different, and that might dictate the exact calibration.”
Some in the market have expressed concern that differences between the regimes could lead to trades being reported in real-time in one jurisdiction, and on a delayed basis in the other. Broadly, ESMA requires more trades to be reported in real-time than the FCA – and has a maximum deferral time of four weeks, compared to the latter’s three month limit.
Last year, market participants weighed in on the possibility that differences in the UK and EU regimes could lead to arbitrage trades.
READ MORE: Simpler bond liquidity assessments diverge on either side of the Channel
“We’re aware that we have to be mindful of the majority of participants who are operating across borders and jurisdictions,” Relleen noted.
Transparency regimes were essential introductions ahead of the bond consolidated tape go-lives in both regions. The UK’s tape, operated by Etrading Software, began operations in June. According to Francesco Cicero, CEO of EU operator FairCT, Europe’s tape should be working from January.
READ MORE: FILS Europe: Bond CTPs fight against ‘free riders’ and ‘pollution’
©Markets Media Europe 2026








