The long road to a UK consolidated tape

The FCA's call for input on the contractual arrangements underpinning the UK equity consolidated tape closes tomorrow, 18 September. It covers two unglamorous but decisive points, how income sharing with data contributors will work in practice, and what operating hours the tape provider will run to. Easy to miss against the bigger headlines. But the deadline is worth pausing on, because it marks another step in a project that has taken the best part of two decades to get this far. I was a very young man when all this began!

Trescore's founder spent several years as head of trading at an investment bank before moving into wealth and platform leadership, and the absence of a consolidated tape was a daily, practical problem long before it became a policy one. Building a complete picture of where liquidity actually sat meant stitching together feeds from a dozen venues by hand, each with its own format and its own price. A single tape was the obvious fix. It just took the industry twenty years to build one.

A promise that stalled.

The idea itself goes back to the original MiFID framework in 2010, one place to see a complete, real-time record of trading activity across a market rather than piecing it together venue by venue. MiFID II carried the ambition forward in 2018, mandating consolidated post-trade data across EU instruments and building out the infrastructure, APAs, CTPs, common data standards, to support it.

It didn't happen. For over a decade the project stalled on data quality, on a fragmented landscape of venues each running their own proprietary feeds and formats, and on unresolved questions about licensing and cost. The MiFIR Review amendments that finally addressed this only entered force in March 2024, more than ten years after the original proposal.

The UK takes its own path.

Post-Brexit, the FCA had room to design its own approach rather than wait for a pan-European solution, and it took a narrower, phased route. Bonds first, equities second. CP23/15 in July 2023 set out the framework for a UK bond consolidated tape, with CP23/33 that December finalising the rules and the payment structure.

What followed was a real procurement process, not just a policy paper. The FCA opened tender for a bond tape provider in March 2025, ETS Connect UK won it in August, a legal challenge delayed the contract award, the High Court lifted the suspension in December, the contract was signed in January 2026, and ETS Connect UK was authorised as the UK's bond consolidated tape provider in May. The tape launched on 22 June 2026. It now has 1.6 million subscriptions, a genuine proof of concept for the model, and a sharp contrast with the EU's equivalent effort, where ESMA only expects to start searching for an equities provider in the second half of 2026.

Now the harder problem, equities.

The FCA published CP26/30 and CP26/31 on 31 July 2026 as a package, alongside an interim Market Activity Reporter giving daily UK equity trading volumes while the full tape is built.

CP26/31 finalises the core framework rather than proposing it. The equity tape will carry both post-trade data and attributed best bid and offer pre-trade data, a firmer commitment than the bond tape needed to make. And the tape provider will be required to share a portion of its income with the venues and firms contributing data to it, a change from the FCA's original thinking and a concession to the industry's cost concerns.

Two pieces are still genuinely open. Whether to include standalone systematic internaliser quotes, displayed separately from the rest of the pre-trade data, is out for consultation until 16 October. And the contractual detail behind income sharing and operating hours, the subject of tomorrow's deadline, will shape how the economics actually land for data contributors once the tape is live. A further consultation on how that shared income gets distributed is expected this autumn.

What comes next.

The final rules take effect from 31 July 2026. Procurement for the equity tape provider is expected to open in early 2027, with the tape itself targeted for launch in 2027 or early 2028, on broadly the same 18-month build cycle the bond tape followed from contract to launch.

For trading venues, APAs, and anyone consuming UK market data, the direction is no longer in doubt. The framework is set, the bond tape has shown the model works, and what's left is implementation detail, income sharing, hours, SI treatment. That detail is exactly what's being consulted on now, and the window to influence it is short.

If you want to talk through what the equity tape means for how you price, distribute or consume UK market data, get in touch with your usual Trescore contact before the 18 September deadline on contractual arrangements, or the 16 October deadline on SI quotes.

This is general information rather than legal, regulatory or tax advice, and reflects our reading of CP26/30 and CP26/31 while parts of the consultation remain open. Please take specific advice before relying on any of this for a decision that affects your firm.