Nearly 2 years after the European Commission first proposed changes to MiFID II and MiFIR, EU legislators have finally agreed what those changes should be.
The areas of change are wide-ranging – they include changes to non-equity transparency requirements, the share and derivatives trading obligations, as well as setting a framework for consolidated tape providers for all asset classes and introducing a ban on payments for order flow.
What is more, things are suddenly moving into the fast lane. Timing will be a particular challenge for firms because the changes to MiFIR enter into force 21 days after publication in the Official Journal (which is expected towards the end of Q1 2024). There appears to be no transition period, despite the fact that many of the amendments will only work once underlying technical standards have been amended or newly produced. So firms will have to assess what changes they can reasonably implement in time. Some regulatory forbearance – either public or between firms and their own supervisors – will likely be required.
Read our summary of the key amendments on our Client Knowledge Portal.