20 April 2017
We highlight the key milestones your business needs to work towards over the coming nine months to achieve timely compliance with MiFID II.
With an implementation date of 3 January 2018 for MiFID II, the deadline for readying your firm for the required changes is rapidly approaching. However, in a recent survey carried out by our colleagues at Moore Stephens LLP, it was found that only 7% of firms had started their implementation plans and more than half did not even have a plan in place yet to achieve timely compliance.
This article highlights the key milestones you need to work towards over the coming nine months.
While the transposition of the Directive into national law is in progress, the FCA has now published its first Policy Statement. Some parts of the statutory instruments are already in place and the FCA has already invited firms to start submitting their applications for a variation of permission or a new authorisation. Firms in scope of MiFID II are encouraged to submit applications before 3 July 2017 in order to be authorised by 3 January 2018.
For firms looking to submit passport notifications, the FCA will open the appropriate gateway on 31 July 2017. All MiFID II passporting notifications must be made by 2 December 2017 in order to be compliant on implementation day.
The FCA has issued revised forms and guidance for all applications and notifications tailored to meet the specific requirements under MiFID II, which are quite onerous, especially for firms seeking to get authorised for the very first time. Firms will need to demonstrate how they will be able to meet all Conduct of Business and prudential requirements both initially and on an ongoing basis.
By now we hope firms have started identifying the changes being introduced by MiFID II that are relevant to their business. If not, we can assist with our comprehensive MiFID II gap analysis and business model review to assess the impending changes and, where required, to submit the relevant applications and notifications on time.
We recommend firms take action now, as failing to obtain the correct permissions or passports before 3 January 2018 will prevent you from conducting regulated activities or providing cross border services.
MiFID II Academy
Our colleagues at Moore Stephens LLP have launched a MiFID II Academy. Signing up to this free Academy allows you access to their dedicated MiFID II microsite encompassing a comprehensive set of tools, insightful articles and exclusive access to seminars and workshops.
Please click here to register.