Clifford Chance

MiFID2 – UK implementation update

6 December 2016

As the MiFID2 juggernaut rolls into the national implementation phase the UK authorities are now in fourth gear on the production of UK implementation measures. While MiFIR and most of the accompanying Level 2 delegated acts and technical standards will apply directly in Member States, requiring no national implementation, the MiFID2 Directive itself is not directly applicable and will require amendment of national laws. The MiFID2 delegated Directive (dealing with the safeguarding of financial instruments and client funds, product governance and fees and commissions) also requires national transposition measures. Here we provide an overview of the changes the UK will make in order to implement the MiFID2 package of reforms and focus in particular on key aspects of the new conduct of business regime where the changed UK landscape is likely to have a significant impact for a wide range of firms.

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