CP26/39 income sharing and incident reporting for CTPs
See how the FCA proposes to split consolidated tape income among data contributors, who the paper is relevant to, and what to do before responses close on 17 December 2026.
Michaela Clarke
Operations & Compliance Coordinator
On this page
Key dates and milestones
What happens, and when
CP26/39 consultation closes
Responses to the proposed income sharing split and incident reporting extension must be submitted by this date via the online form or by email to cp26-39@fca.org.uk.
FCA sourcePS26/2 incident reporting rules come into force
The final rules and guidance on operational incident and material third-party reporting, which the CP26/39 incident reporting proposals build on, take effect on this date.
FCA source
What firms should do now
4 steps to get ready
- 1
Model where your trades sit in the proposed split
Work out whether your trade value would fall in the 50% trading venue and APA pool, the CLOB and periodic auction pool, or the smaller venue threshold of under 5% of value traded.
- 2
Decide whether to respond before the deadline
Board or senior management should decide before 17 December 2026 whether to submit a response, focusing on the 4.5 weighting and the 5% threshold where your data supports a specific position.
- 3
Confirm data submission readiness as a new contributor
If you are a new data contributor, plan to send data to the equity CTP as soon as possible from the time you start operating, as the source sets this expectation.
- 4
Compare incident reporting against the proposals
If you are or may become a CTP, review Chapter 3 of CP26/39 against your current incident reporting arrangements, alongside the PS26/2 rules.
At a Glance
CP26/39 is an FCA consultation paper proposing how the equity consolidated tape provider (CTP) should split its shared income among data contributors, and extending enhanced operational incident reporting requirements to all CTPs. The equity CTP must share a portion of its income with data contributors, a requirement set in the July 2026 Policy Statement, and new data contributors must provide data to the CTP as soon as possible from the time they start operating. Responses to the consultation close on 17 December 2026, and responding is optional.
The FCA is introducing an equity consolidated tape (CT) to bring together and distribute UK trading data in a single feed. The UK bond CT launched in June 2026.
The FCA says it will consider all responses and aims to publish a Policy Statement in spring 2027. It plans for the equity CT to start operating in 2027 or early 2028.
What Has Changed
Status
CP26/39 is a consultation paper. It makes proposals and seeks views, so none of its proposed rules are in force. The FCA aims to publish a Policy Statement in spring 2027.
Income split
The FCA proposes to split the pool of shared income in half. 50% of the total income to be shared would be distributed among all trading venues and APAs that contributed post-trade data in the relevant period, according to their share of the total value of trades submitted. The other half would be reserved for CLOB and periodic auction trading systems. The FCA proposes a 4.5 weighting for trades reported by smaller venues, defined as those accounting for less than 5% of the value of trades provided to the equity CT, excluding NPFT and TNCP trades. It estimates this would roughly triple smaller venues' share of total income, from 11.8% to 34.6%.
Incident reporting
The FCA proposes extending enhanced operational incident reporting requirements to cover all CTPs. It says this builds on existing requirements to help make sure significant operational incidents are reported to it consistently. Chapter 3 of CP26/39 sets out the detail.
Timetable
The share of income to be paid to data contributors will be specified in the FCA's 5-year concession agreement with the equity CTP. The FCA will confirm its requirements in a Feedback Statement in early 2027. It will also start a post-implementation review 2 years after the equity CT starts operating.
Key figures and dates in CP26/39
| Item | Figure | What it covers |
|---|---|---|
| Share of the total income to be shared, distributed among all trading venues and APAs | 50% | Proposed; divided by share of the total value of trades submitted to the equity CT |
| Smaller venue threshold | Less than 5% of value of trades | Excludes NPFT and TNCP trades |
| Proposed weighting for smaller venue trades | 4.5 | In line with the EU, as proposed by the FCA |
| Smaller venues share of total income | 11.8% to 34.6% | FCA estimate under the 4.5 weighting |
| Estimated distribution under the 4.5x model: CLOB and periodic auction trading systems | 60.4% | APAs 24.9%; other trading systems 14.7% |
| Consultation closes | 17 December 2026 | Respond online or email cp26-39@fca.org.uk |
Who Needs to Act
The equity CTP carries the main obligation. The July 2026 Policy Statement already requires it to share a portion of its income with data contributors, and CP26/39 proposes how that income is split. New data contributors must provide data to the CTP as soon as possible from the time they start operating.
The FCA says the consultation is relevant to trading venues, Approved Publication Arrangements (APAs), systematic internalisers (SIs), and current and potential CTPs, trade associations and other interested stakeholders in UK equity and bond markets. Under the proposed model, trading venues and APAs that contribute data are eligible to receive income. The FCA expects the incremental cost of sending data to be small for new venues, because the equity CTP will connect to a feed they already establish.
Evidence to Prepare
A firm affected by the proposals should know where it sits in the proposed model: a trading venue or APA contributing post-trade data, a CLOB or periodic auction trading system, or a venue that could fall under the 5% smaller venue threshold. The FCA proposes that where an APA reports a trade on behalf of a trading venue, the trading venue receives the income from that trade, and that NPFT and TNCP trades are excluded when measuring the 5% threshold. Firms that are or may become CTPs should read Chapter 3 on operational incident reporting against their current incident reporting arrangements.
The key pitfall is treating the proposals as settled. The FCA is still consulting, and the actual share of income will be specified in the concession agreement rather than in CP26/39. The 4.5 weighting is a proposal made in line with the EU, and the FCA acknowledges a trade-off: larger trading venues and APAs would receive a lower proportion of shared income. Missing the 17 December 2026 deadline also means missing the chance to influence rules the FCA will use responses to finalise.
What Firms Should Do Now
| Action | Owner | Timing | Evidence |
|---|---|---|---|
| Work out whether your trades would fall within the 50% pool for trading venues and APAs, the CLOB and periodic auction pool, or the smaller venue threshold. | Head of Market Data or Chief Financial Officer | Before drafting a response | CP26/39, Chapter 2, paragraphs 2.5 to 2.7 and 2.16 |
| Respond to the consultation through the FCA's online form or by email to cp26-39@fca.org.uk, if you want to put your position on the 4.5 weighting and the 5% threshold. | Compliance lead or Regulatory Affairs | 17 December 2026 | CP26/39, paragraph 1.15 |
| Provide data to the equity CTP as soon as possible from the time you start operating, if you are a new data contributor. | Head of Operations or Head of Trading | From the time you start operating | CP26/39, Chapter 2, paragraph 2.17 |
| Review the incident reporting proposals in Chapter 3 against your current incident reporting arrangements, if you are or may become a CTP. | Chief Operating Officer or Head of Operational Resilience | Before 17 December 2026 | CP26/39, Chapter 3 |
MEMA View
The board of any trading venue, APA or SI that expects to be involved should decide before 17 December 2026 whether to respond to CP26/39. The 4.5 weighting and the 5% threshold matter most. A larger venue or APA would receive a lower share under the weighting, and a smaller venue a higher one. We would quantify the firm's own position against the FCA's estimates before taking a view.
We would respond only on points where the firm's data supports a specific position, and keep the response short. A firm should also decide whether it is likely to be a CTP or a data contributor, because the incident reporting proposal applies to all CTPs while the income split affects data contributors. Responding costs time now, but silence leaves no record of your view when the FCA finalises its rules.
If you are working out where your trades sit in the proposed income split, MEMA can model your position and support your response, and our team also provides ongoing FCA compliance support on incident reporting.
For context on how these market structure changes fit into wider supervisory work, see our summary of the FCA's 2026 compliance priorities.
Source Evidence
| Source | Document type | Published | Why it matters |
|---|---|---|---|
| CP26/39: Income sharing distribution and operational incident reporting for consolidated tape providers | FCA consultation paper (CP26/39) | 2026-10-29 | The proposed income split, 4.5 weighting, incident reporting proposal and 17 December 2026 response deadline. |
Disclaimer
This article is for general information only and does not constitute legal or regulatory advice. Firms should assess the application of regulatory requirements by reference to their permissions, products, customers and operating model.
How MEMA Can Help
MEMA can estimate where your trade volumes would sit under the proposed 50% and CLOB pools, and whether the 5% smaller venue threshold would apply to you. We can also draft your consultation response and compare your incident reporting with the CP26/39 proposals. Book a free scoping call.
Frequently asked questions
Is CP26/39 a final rule that firms must comply with now?
No. CP26/39 is a consultation paper, and the FCA says it makes proposals and seeks views. The FCA aims to publish a Policy Statement in spring 2027. The requirement that the equity CTP must share a portion of its income with data contributors is different, because the FCA set it in the July 2026 Policy Statement.
When does the consultation close and how do I respond?
The consultation closes on 17 December 2026. You can respond using the FCA's online response form or by emailing cp26-39@fca.org.uk. The FCA says it will review all responses and use them to help finalise its rules. Responding is optional.
What does the 4.5 weighting mean for smaller trading venues?
The FCA proposes multiplying the value of trades reported by smaller venues by 4.5. Smaller venues are those whose trades account for less than 5% of the value of trades provided to the equity CT, excluding NPFT and TNCP trades. The FCA estimates this would roughly triple their share of total income, from 11.8% to 34.6%, while larger venues and APAs receive a lower proportion.
When will the equity consolidated tape start operating?
The FCA plans for the equity CT to start operating in 2027 or early 2028, following its Policy Statements, procurement documents and the procurement process. It will begin a post-implementation review 2 years after the equity CT starts operation, to assess whether the economic model and regulatory framework, including income sharing, remain appropriate.
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