Phase 2 date
The FCA says phase 2 takes effect on 30 November 2026.
Buyer-intent answers
FCA · short selling · reporting migration
FCA Short Selling Phase 2: Prepare for Bulk Position Submissions by 30 November 2026
A source-backed migration checklist for investment firms and reporting teams preparing position data, identifiers, controls and test files for the FCA short-selling phase-2 bulk-submission change.
Primary query: FCA short selling bulk submission 30 November 2026 ESS prepare · Updated 2026-09-07
Direct answer
What should a firm prepare before the FCA short-selling bulk-submission change on 30 November 2026?
The FCA’s phase-2 short-selling system change takes effect on 30 November 2026 and will allow multiple positions to be uploaded and submitted in one bulk submission. Firms should inventory their current position-reporting export, identifiers and control totals, preserve a known-good sample corpus, then compare it with the FCA’s updated operational guidance and ESS requirements before cutover. The FCA indicated that supporting operational documentation would be updated ahead of phase 2, so the migration check should be rerun when that documentation changes.
Practical sequence
What to do next
- 01
Inventory every system or spreadsheet that produces net-short-position data for FCA submission and identify its business owner.
- 02
Create a small representative test corpus covering multiple positions, identifiers, dates and common exception cases without using production submission as the test environment.
- 03
Define control totals and duplicate checks that can prove the bulk file represents the same intended positions as the existing single-position workflow.
- 04
Compare the test corpus with the latest FCA operational guide and ESS requirements when the phase-2 documentation is updated.
- 05
Run an acceptance and rollback review before 30 November 2026, keeping the validation evidence and human compliance sign-off.
Decision facts
Operational change
Phase 2 updates position reporting so users can upload and submit multiple positions in a single bulk submission.
Documentation
The FCA has produced supporting operational documentation and planned updates ahead of the phase-2 cutover.
Boundaries
- — Exact bulk-file fields, validation behaviour and operational procedures must follow the latest FCA documentation available at the time of implementation.
- — This page is a reporting-migration preflight, not regulatory or legal advice and does not submit positions to the FCA.
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