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Sub practice

MiFID Review

The MIFID Review has commenced and it is clear from the volume of proposals that have already been published that many aspects of the MiFID II framework are on the table for review.

Implementing MiFID II (Markets in Financial Instruments Directive) and MiFIR (Markets in Financial Instruments Directive) by 3 January 2018 was a significant undertaking for the finance industry as it overhauled existing regimes and addressed all investment services and MiFID financial instruments. Both the directive and the regulation prescribed that the European Commission (Commission) would review the effectiveness and impact of several requirements in relation to investor protection and market structure and transparency topics. The Commission commenced that process in early 2020, and whilst the review was not intended to cover the entirety of the existing regime, it was always going to be wide ranging.

Coming only two years after the regime was implemented, many within the industry (including regulators) are still facing uncertainties and implementation challenges which, in a number of areas, have been compounded by Brexit. As a result, market participants have been keen to ensure that this review clarifies existing requirements rather than providing for wholesale re-writes. However, the volume of proposals published already indicates that many aspects of the MiFID II framework are on the table for review, and the end legislative outcome could involve some significant and substantial revisions to the regime. Focus, at least in the short term, will be on measures that form part of the Commission’s overall Covid-19 recovery.

Our Financial Services Regulatory team are producing briefing papers on the main proposals as they develop, drawing out key changes and impacts for market participants, which can be accessed via the links below. If you would like to receive more information please get in touch with your usual A&O contact.

News & insights


Publications: 15 OCTOBER 2020

The MiFID Review - a ‘stocktake’ on recent publications impacting wholesale financial markets participants

Over the last two months, the industry have seen a number of proposals from both the European Commission and ESMA in relation to the MiFID Review.

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Publications: 17 APRIL 2020

MiFID 2.5 (or 3) – What you need to know during 2020

As required by the existing framework, the MiFID II review has begun but what is not clear at this stage is whether it will be a complete re-write or simply MiFID 2.5. 

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  1. European Financial Services Regulatory Team of the Year - winners at the IFLR Europe Awards 2018 and 2020, Tier 1
  2. Tier 1, Legal 500, Financial Services: Non-contentious/Regulatory 2021
  3. Tier 1, IFLR, Financial Services Regulatory: Non-contentious, 2021