MiFID II Maturity · Investor Protection and Financial Market Transparency
Your MiFID II framework measured requirement by requirement, and costed into an action plan.
10 themes, a 5-level scale. And the action that moves each level to the next.
The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.
MiFID II Maturity · Investor Protection and Financial Market Transparency
10 themes, 5-level scale.
Nordhavn Industries
53 / 100
They measure their maturity with Datamensio
An example
This could be your situation.
Take one company as an example: three sites, three spreadsheets, no shared answer.
Nobody can consolidate.
Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.
Three weeks, a single base.
One Directive 2014/65/EU (MiFID II) and Regulation 600/2014 (MiFIR), applicable since 3 January 2018 assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.
Two costs avoided before being committed.
A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.
What it saved them
- 3sites measured on the same base, instead of three questionnaires to reconcile
- 2duplicate actions caught before the spend
- 1committee report, with no manual rework
These figures are an example. They could be yours.
The standard imposes processes. Datamensio says where you stand.
01
The framework is already written
Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.
02
The score lands the same day
Online, by self-assessment link or in interview. Theme by theme, comparable over time.
03
The gap becomes a costed plan
Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.
04
Progress can be demonstrated
Campaign after campaign, against your target and against your own past. That is what your board asks for.
The maturity scale
One level, the next, and the action that links the two.
It is this mechanism (one level, the level above, and the action linking the two) that turns a finding into a trajectory.
Is the target market defined by the manufacturer used and fed back by distributors?
- N1
The target market is defined in product documentation but is not used by distribution teams.
- N2
The target market is passed to distributors. Its use at the point of sale depends on individual teams and is not controlled.
- N3
The target market is built into the subscription journey. Sales outside the target market are identified and justified.
- N4
Sales outside the target market are tracked with figures and formally reported back to manufacturers at set intervals.
- N5
Distributor feedback feeds into product review and leads to documented adjustments of the target market or distribution strategy.
Action to move from L2 to L3
Build target market criteria into the subscription tool with a blocking or justifiable control point, and put the review of out of target sales on the agenda of the quarterly product committee.
« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Director, CCI 94CCI Île-de-France
« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Maja SucekChief Operating Officer, Interreg Danube
Rarely on its own
Frameworks combine. Put several together to cover your business, or have the AI write yours.
Take your first measurementon MiFID II.
What this framework covers
MiFID II is Directive 2014/65/EU, complemented by the MiFIR regulation, applicable since 3 January 2018. It pursues two distinct objectives. Investor protection first: product governance with target market definition, suitability and appropriateness assessment, ex ante and ex post disclosure of costs and charges, oversight of inducements, recording of communications, management of conflicts of interest. Market transparency second: transaction reporting obligations, pre and post trade transparency, the trading obligation, best execution with supporting evidence.
In practice, the framework is difficult to steer because it plays out on the ground, not in the procedures binder. Does the target market defined by the manufacturer actually filter down to the adviser making the sale, and does it flow back up as distributor feedback? Are suitability questionnaires updated when the client’s circumstances change, or have they lain dormant since subscription? Is the best execution policy demonstrable through monitoring data, or merely asserted in a document? These three questions generally separate organisations that have a framework from those that have documentation.
Two developments shape the topic today. The 2024 MiFID II / MiFIR review removed the consolidated data regime as it previously existed and introduced a European consolidated tape, while tightening the rules on payment for order flow. At the same time, sustainability requirements have entered the suitability process: client preferences on this must be collected and factored into the recommendation. Many organisations have added a question to the questionnaire without revisiting the recommendation logic that follows.
The maturity assessment answers a different question from compliance control. Control asks: is the requirement satisfied, yes or no. The assessment asks: at what level of maturity does each practice sit, and what precise action moves it to the next level. An organisation can be formally compliant on cost and charges disclosure while remaining at level 2 on its ability to produce that disclosure without manual rework. It is this gap that the score makes visible, and that the action plan addresses.
In Datamensio, the framework is ready to use and remains yours. You adjust the themes according to your status, whether asset manager, investment firm, distributor or private bank. The AI refines questions and levels, or builds a variant from your internal policies and control reports.
Reference standard: Directive 2014/65/EU (MiFID II) and Regulation 600/2014 (MiFIR), applicable since 3 January 2018
The themes assessed
Governance and organisation of the framework
Allocation of roles between compliance, distribution and control, involvement of the management body, resources allocated, steering through indicators.
Product governance and target market
Definition of the positive and negative target market, distribution strategy, periodic product review, distributor feedback to manufacturers.
Suitability and appropriateness
Collection of knowledge, experience, financial situation, objectives and risk tolerance, updating, suitability report, sustainability preferences.
Client information and costs
Ex ante and ex post disclosure of costs and charges, cumulative effect on return, client classification, clear and non misleading nature of communications.
Inducements and conflicts of interest
Oversight of inducements and the quality enhancement test, conflicts register, sales staff remuneration policy, gifts and benefits.
Best execution
Execution policy, factors and weightings applied, selection and monitoring of execution venues, control of the quality obtained, evidence on client request.
Transparency and transaction reporting
Pre and post trade transparency, transaction reporting to the regulator, quality and completeness of fields, reconciliation and correction of rejections.
Recording and retention of communications
Recording of telephone and electronic communications related to orders, scope covered, retention period, ability to retrieve records.
Staff training and competence
Knowledge and competence requirements for staff providing advice or information, training pathways, assessment, traceability.
Control, remediation and continuous improvement
Second level control plan, complaints handling, monitoring of remediation plans, use of findings to improve practices.
A short version of the framework is available for the online self-assessment.
Frequently asked questions
Can MiFID II be certified?
No. It is an EU directive transposed into national law, whose compliance is monitored by the regulator, not by a certification body. The assessment measures the maturity of your framework and prepares you for regulatory or internal control reviews.
What is the difference between this assessment and a compliance control?
Control checks whether a requirement is met and concludes with a gap. The assessment places each practice on a progressive scale and indicates the action that moves it up one level. The two complement each other: the assessment prepares and prioritises, control validates.
How long does the assessment take?
The short version can be completed in one working session. The full version, run collaboratively with compliance, distribution and middle office, spans one to two weeks, most of the time being spent collecting input from the teams.
Can the framework be adapted to our status?
Yes. Applicable requirements differ between asset manager, investment firm, distributor and private bank. You adjust the themes, questions and levels, and the AI can build a variant from your policies and control reports.
Can several entities or networks be compared?
Yes. The same framework is rolled out to several business units, with a score per theme and a benchmark between entities and against previous assessments. A cross entity roadmap consolidates action plans without duplicating shared workstreams.
How does the assessment handle sustainability preferences?
They are assessed within the suitability theme, beyond mere collection: effective consideration in the recommendation, traceability of the client’s choice, consistency with product information. This is also the point of intersection with SFDR.
Where is the data hosted?
In France, with OVH, with backup at Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European solutions.