The MiFID/MiFIR Review was a product of the EU's Capital Markets Union (CMU) Action Plan, published in September 2020. The European Commission published two legislative proposals amending MiFID II and MiFIR respectively, which were eventually finalised in 2024 as Directive (EU) 2024/790 (the "MiFID II Amending Directive") and Regulation (EU) 2024/791 (the "MiFIR Amending Regulation"). This legislative package is commonly known collectively as the "MiFID/MiFIR Review". The amendments contained in these Level 1 legislative acts, in conjunction with detailed Level 2 delegated legislation to be adopted in connection with them, are designed with a view to creating more efficient and integrated EU capital markets.

This Guide has been produced for AIMA members in conjunction with Sponsoring Partner Travers Smith, to highlight some of the key areas arising from the EU MiFID/MiFIR Review which are relevant to buy-side firms seeking to access the EU wholesale markets. In selecting the relevant topics covered by this Guide, we have focused on the priority areas in relation to which AIMA has been engaging with EU policymakers over the last few years. This Guide is limited to considering changes arising directly from the MiFID/MiFIR Review and does not discuss wider EU initiatives (for example, under the EU Savings and Investments Union proposals) which may also have a further impact on some of the issues discussed.

In many cases, the direct obligations arising in relation to each of the topics covered in this Guide will fall on EU sell-side counterparties or operators of EU market infrastructure, although there may be knock-on effects for buy-side firms dealing with those entities. In a limited number of areas, the revised rules may impose new obligations (or in some cases, new freedoms) directly on buy-side firms and therefore will be directly applicable to some AIMA members. More broadly, AIMA members may find this guide helpful in explaining the relevance of the changes in each topic area for the buy-side or the sell-side, as well as the underlying rationale and intended objectives of the legislative amendments.

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  Adam Jacobs-Dean

  Managing Director, Global Head of Markets, Governance and Innovation

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  Aniqah Rao

  Associate Director, Markets, Governance and Innovation