The MiFID II requirements on investment advice and brokerage once again become more complex: On 27.1.2022, ESMA published a consultation paper on revised guidelines on the MiFID II suitability assessment, incorporating the new ESG requirements in the context of the suitability assessment. In addition, the final version of the revised ESMA guidelines on the MiFID II appropriateness test and execution-only requirements was published at the beginning of January.
The discussion on payments for order flow has once again put a spotlight on the issue of inducements. In November, the EU Commission presented a legislative proposal to ban inducements in this context, which raises the question of the scope and consequences of such a (temporary?) partial ban.
We are looking forward to discussing the perspectives of different stakeholders.
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