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17. Mastering Direct Reporting: Article 26(7) Always Gave You the Right - Part 1

Article 26(7) of MiFIR has always given firms the right to report direct, and 2025 is the year to actually use it. 

/ Summary

This session sets out why ARMs became the default in 2018 (deadline panic, XML complexity, perceived lower risk), why the original justifications no longer hold, and how the legal, technical and commercial landscape has shifted in your favour. We walk through the seven step direct reporting workflow (capture, transform, enrich, validate, package, submit, reconcile), the technical connectivity stack (RTS 22 XML v5.x, SFTP to the FCA MDP, TLS 1.2+, ACK and NACK feedback) and the three lines of defence framework. A real client case study of a UK brokerage shows the total cost (£27,190 FCA fee plus £66k Control Now service) and quantifies approximately £194,810 of savings over three years versus the incumbent ARM. The strongest commercial case yet for taking control of your own reporting chain.

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