MiFID Gap Analysis & Roadmap

A MiFID II gap analysis is a structured assessment that compares all regulatory relevant areas of your institution against the requirements of MiFID II, MiFIR and the associated delegated acts.

The analysis covers these core areas:

The result is a detailed gap report with prioritized action recommendations that serves as the foundation for roadmap development.

Roadmap development follows a systematic process that accounts for regulatory urgency, implementation complexity and available resources.

The process comprises four steps:

1. Prioritization by criticality: Each identified gap is assessed by regulatory risk (fines, supervisory measures), impact on business processes and dependencies on other measures.

2. Phase planning: Measures are organized into sequential implementation phases — from quick wins (immediately actionable) through medium-term adjustments to long-term system transformations.

3. Resource and budget planning: Required capacities, external support and investments are calculated for each phase. Synergies with ongoing projects (such as DORA, GDPR or MiFIR II adjustments) are actively leveraged.

4. Milestones and KPIs: Measurable interim targets, responsibilities and checkpoints are defined for each measure. A monitoring framework ensures progress tracking.

The roadmap is aligned with the board and compliance function and regularly updated to reflect evolving regulatory requirements.

The MiFIR II regulation adopted in March 2024 introduces significant changes that must be factored into any current gap analysis.

Key changes:

A current gap analysis must incorporate these changes and the roadmap must prioritize accordingly, as some requirements carry tight implementation deadlines.

The scope and focus of a MiFID gap analysis varies considerably depending on the business model and license scope of the institution.

Typical differences:

We tailor the analysis framework to your specific business model, client structure and license scope to ensure relevance and efficiency.

Based on our project experience, certain compliance gaps occur frequently across institutions.

The most common gaps:

The gap analysis uncovers these weaknesses and quantifies the action required so that resources can be deployed effectively.

Duration depends on the scope of the business model and the complexity of the existing process landscape. Typical project timelines:

The process comprises five phases:

1. Scoping and kick-off (weeks 1‑2): Definition of analysis scope, identification of relevant business areas and contacts, provision of the document base.

2. Document analysis and interviews (weeks 3‑6): Review of internal policies, process documentation and IT landscape. Structured interviews with business units, compliance and IT.

3. Gap identification and assessment (weeks 5‑8): Systematic comparison of current state against regulatory requirements. Assessment of each gap by criticality and complexity.

4. Roadmap development (weeks 7‑12): Prioritization of measures, phase planning, resource calculation and milestone definition.

5. Results presentation and alignment (weeks 11‑16): Presentation to board and supervisory body, roadmap alignment and agreement on next steps.

An effective MiFID compliance roadmap actively leverages overlaps with parallel regulatory requirements to avoid duplication and reduce costs.

Key synergy areas:

Our roadmap explicitly identifies these synergies and proposes integrated implementation workstreams that address multiple regulatory requirements simultaneously.