What Is the FCA Proposing?
The Association for Financial Markets in Europe (AFME) has formally supported the Financial Conduct Authority’s consultation on creating a UK equity consolidated tape, while urging broader reform of the country’s market data pricing framework.
The FCA opened its consultation on 19 November 2025, with feedback due by 13 February 2026. The regulator is targeting a 2027 launch for the equity consolidated tape as part of its post-Brexit overhaul of capital markets rules under the Financial Services and Markets Act 2023.
In its submission, AFME supported including both post-trade data and attributed pre-trade data from launch. It also endorsed publishing end-of-day consolidated post-trade data ahead of the tape’s formal go-live date, giving firms an early reference point while the full infrastructure is finalised.
The trade body argued that the tape should be operated by a single provider selected through a competitive tender process to avoid fragmentation. It also warned that excessive technical complexity or high costs could undermine adoption among market participants.
Investor Takeaway
Why Is Market Data Pricing Central to the Debate?
The consolidated tape discussion cannot be separated from the long-running dispute over market data costs. Under MiFID II, exchanges are required to provide data on a “Reasonable Commercial Basis” (RCB). Large banks and asset managers have argued for years that pricing remains opaque and expensive, particularly for high-quality real-time feeds.
Exchange groups counter that data revenues fund market infrastructure and, in many cases, exceed cash equity trading income. That revenue dependence makes any reform politically and commercially sensitive.
AFME explicitly linked its support for the tape to changes in the UK’s RCB framework. Without adjustments to how input data is priced, market participants warn that a consolidated product could inherit inflated costs from venue-level feeds, limiting its intended efficiency benefits.
The UK’s initiative follows similar legislation in the European Union, where consolidated tape rules were finalised under Capital Markets Union reforms. The EU model mandates post-trade data contribution and provides for a single tape per asset class selected through competition, alongside revenue redistribution mechanisms.
How Does Fragmentation Fit Into the Reform?
The consultation forms part of a longer effort to address structural data fragmentation in European equity markets. Since MiFID I in 2007, trading has been dispersed across regulated markets, multilateral trading facilities and systematic internalisers. While competition increased, no mandatory consolidated feed was introduced.
As a result, firms have had to assemble their own aggregated view of prices and transactions across venues, relying on multiple commercial data feeds. That patchwork model persisted in the UK after Brexit, leaving the FCA to revisit inherited EU rules within its new domestic framework.
By mandating a consolidated tape under regulatory authority, the FCA is attempting to create a single reference point for UK equities. Previous commercial attempts in Europe failed because vendors could not secure full venue participation without a legal requirement to contribute data.
One sensitive element of the UK proposal is attributed pre-trade data. Including attribution would identify the liquidity provider behind displayed quotes. Some market participants have historically resisted this on the grounds that it could reveal trading strategies. AFME’s backing of attribution indicates that, under the proposed structure, its members see transparency gains outweighing those concerns.
Investor Takeaway
What Are the Cross-Border Implications?
AFME also called for technical alignment with the EU model where possible. Large banks operating across both jurisdictions would otherwise need parallel systems to comply with differing standards, increasing operational costs.
Major firms active in both the UK and EU markets rely on integrated trading and data infrastructure. Divergent reporting formats, attribution rules or distribution standards could complicate that setup.
Exchanges, including the London Stock Exchange, Cboe Europe and Euronext, are central stakeholders in the consultation. Each derives substantial revenue from proprietary data products. A single consolidated tape provider could centralise aspects of distribution, affecting how consolidated pricing power is exercised.
The next stage involves the FCA reviewing consultation responses and setting tender specifications for the tape operator. Established data vendors and exchange-linked entities are expected to compete for the role.
While there is broad agreement on the need for a consolidated view of UK equity trading, the outcome will hinge on whether the regulator is willing to revisit the wider market data pricing framework. The tape’s structure may be settled through consultation, but the economics of transparency will depend on how far reform extends beyond the tape itself.
