There is now less than a month to go until MiFID II starts, on 3rd January 2018. Investment Firms who will have to comply with many parts of the rules, such as the different data reporting strands, best execution, client protection, market structures and others, have a great deal of work to do in order to be ready. The research un-bundling rules are causing some headaches, as reported here on the Reuters web site. And transposition, as previously reported here, is still not completed in all member states, as outlined here on the Finance Magnates web site.

In the commodity and energy markets, while there are less requirements for those who make use of the Ancillary Activity exemption under Article 2(1)j of MiFID II, there is still work to be carried out. Firstly, each firm using the exemption must notify their National Competent Authority of such use. Most recently, the FSMA of Belgium has issued their form (see here). In addition, it is necessary to comply with the position limits rules (see here) and also to comply with the indirect position reporting requirements. These requirements are still evolving to some degree. In addition, even at this late stage, not all limits are set. There is therefore a great deal to be mindful of in the next few weeks.