MiFID Ongoing Training & Compliance Monitoring

Under MiFID II, investment firms must ensure that staff in investment advice, portfolio management and sales possess the required competence. ESMA guidelines specify that investment advisors and sales representatives must demonstrate competence in client advisory, legal foundations of securities business, knowledge of financial instruments and tax fundamentals. Competence is not a one-time requirement but must be maintained continuously. ESMA requires annual evidence of at least

15 hours of structured continuing professional development. ADVISORI supports institutions in designing and documenting these records so that requirements can be evidenced in a fully audit-proof manner during regulatory examinations.

Effective MiFID compliance monitoring rests on three pillars: First, defined control activities with fixed review cycles – such as sample-based review of suitability statements, verification of cost disclosure or examination of product governance processes. Second, a KPI system with thresholds and escalation levels that quantifies compliance risks and makes them visible early. Third, regular reporting to senior management and the compliance function with concrete action recommendations. ADVISORI helps develop tailored monitoring plans covering all MiFID-relevant processes – from investment advice through transaction reporting to best execution.

MiFID II and ESMA guidelines distinguish several target groups with different competence requirements: Investment advisors need comprehensive knowledge of financial instruments, suitability assessment and cost disclosure. Sales representatives must master product governance and distribution requirements. Compliance officers need in-depth knowledge of all MiFID requirements, including conflicts of interest, remuneration and complaints handling. Senior management in securities business must be able to assume overall responsibility for MiFID compliance. ADVISORI develops specific training modules for each target group, matching the respective role requirements and containing practical case studies.

Efficient competence maintenance combines various formats: Annual foundation training on regulatory updates (ESMA guidelines, national supervisor circulars, legislative changes), supplemented by intra-year short modules on specific topics such as ESG integration in investment advice or new product categories. Documentation must be audit-proof and includes attendance records, learning assessments and individual training plans per employee. A central training register that shows each employee's current competence status, completed modules and outstanding mandatory training has proven effective. ADVISORI sets up these structures and supports integration into existing HR and compliance systems.

During supervisory examinations, regulators typically review the following in the training area: individual competence records for each staff member in securities services, evidence of annual continuing education of at least

15 hours, appropriateness of training content relative to the respective function, and currency of training when regulatory changes occur. In the monitoring area, regulators examine the existence of a documented compliance monitoring plan, execution and documentation of control activities, follow-up on identified deficiencies, and reporting to senior management. ADVISORI prepares institutions for these examinations and ensures all required evidence is complete and audit-proof.

The MiFID training landscape is shaped by several current developments: ESG integration in investment advice (since August 2022) requires training on sustainability preferences and the Taxonomy Regulation. ESMA suitability guidelines were updated in 2023, requiring deeper training on cost information. The planned MiFID III/MiFIR review brings changes to Payment for Order Flow (PFOF ban from

30 June 2026), Consolidated Tape and transparency requirements that must be integrated into training programmes. Additionally, national supervisors continue updating their guidance, requiring adjustments to compliance monitoring. ADVISORI systematically tracks these developments and integrates them promptly into client training and monitoring concepts.

ADVISORI connects training and monitoring into a closed feedback loop: Compliance monitoring results flow directly into training planning – when systematic weaknesses are identified in suitability statement oversight, targeted training modules on suitability assessment are scheduled. Conversely, training content is verified through monitoring – after the institution has conducted training on cost disclosure, correct implementation is specifically checked in the following weeks. This integrated approach includes: development of a combined training and monitoring calendar, definition of feedback loops between both areas, coordinated reporting to senior management and compliance function, and annual overall assessment of both programmes' effectiveness within the compliance risk analysis.