MiFID Adaptation of Sales Management and Process Workflows

MiFID II imposes comprehensive requirements on sales management and distribution governance. Key obligations include the suitability assessment under Art. 25(2) MiFID II, appropriateness testing for execution-only services, product governance obligations under Art. 16(3) and Art. 24(2), inducements rules under Art. 24(7)-(9), and cost transparency with ex-ante and ex-post cost disclosures. ADVISORI analyses existing sales processes to identify regulatory gaps and determine which specific measures are required.

The suitability assessment is the core of the MiFID II advisory process. Advisors must systematically collect information about clients' knowledge, experience, financial situation, investment objectives, and — since August

2022 — sustainability preferences. Results are documented in a suitability statement. ADVISORI helps design processes that embed this assessment seamlessly into the advisory dialogue without interrupting the conversation flow or requiring post-hoc documentation.

MiFID II significantly restricts the receipt and provision of inducements. Commissions and other monetary benefits may only be accepted if they enhance service quality and are transparently disclosed to clients. From June 2026, an inducements ban applies to execution-only services for retail clients. Investment firms must therefore structurally review and adapt their remuneration models, incentive systems, and retrocession arrangements.

Investment firms must provide clients with comprehensive ex-ante cost information before executing a transaction — including product costs, service costs, and inducements. After execution, annual ex-post cost information with actual costs incurred must follow. ADVISORI helps integrate these requirements into existing sales tools and advisory systems so that cost transparency is generated automatically and presented clearly to clients.

Product governance requirements under Art. 16(3) and Art. 24(2) MiFID II oblige manufacturers and distributors of financial products to define and regularly review a target market. Distributors must ensure products are only distributed to clients within the defined target market. This requires close alignment between product management and sales, which ADVISORI supports through clear processes, IT-based checks, and training concepts.

MiFID II requires complete documentation of advisory conversations, suitability statements, and electronic communication records. Efficient implementation is achieved through integration into existing CRM and advisory systems: automatic protocol generation, pre-structured advisory templates, and rule-based plausibility checks. ADVISORI develops documentation concepts that fulfil regulatory requirements while reducing the administrative burden on advisors.

The EU Retail Investment Strategy (RIS) brings significant changes from 2026: an inducements ban for execution-only services, expanded best execution obligations, and stricter cost information requirements. Additionally, ESMA requirements for sustainability preferences in investment advice are increasing. ADVISORI accompanies financial institutions in proactively adapting their sales management so regulatory changes are implemented before they take effect.