Updated edition - AFME & Linklaters implementation guide on MiFIR / MiFID II reforms in the EU and UK

The Association for Financial Markets in Europe (AFME) and Linklaters have updated our joint implementation guide to help EU and UK firms operating in wholesale secondary markets navigate the breadth of developments in the MiFID II / MiFIR space. 

This important update covers key developments (up to the end of March 2025) impacting the UK & EU “MiFID Landscape”. It is intended to help firms operating in wholesale secondary markets identify (and budget for) the breadth of change, divergences and complex implementation timelines. AFME advocacy is referenced in areas that are still being finalised by EU or UK regulators.

The guide focuses on seven key areas:

1. Market structure
2. Transparency
3. Market Data
4. Consolidated Tape Providers
5. Transaction Reporting
6. Investment research 
7. Order execution policies

Although commentary is focused on challenges and impacts for sell-side firms, the guide will be of interest to other firms operating in wholesale markets.

The guide will be periodically updated until the end of 2025 as further regulatory developments crystallise.

Read the updated guide here.

To view Linklaters’ more detailed client notes on the key EU & UK developments in this space, see Linklaters’ UK & EU Wholesale Markets Timeline (accessed via the Linklaters Client Knowledge Portal).