Regulatory separation of research costs under MiFID II
MiFID II Research Unbundling: Separating Research Costs from Execution
Since 2018, MiFID II requires the separation of research costs from trade execution fees. Investment firms must pay for research through a Research Payment Account (RPA) or from their own resources. ADVISORI supports institutions in fully implementing unbundling requirements — from gap analysis through RPA setup to ongoing compliance monitoring.
- ✓Research Payment Account (RPA) setup and management
- ✓Transparent cost allocation and research budgeting
- ✓Procurement governance structures for research procurement
- ✓Ongoing compliance monitoring and regulatory documentation
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MiFID II Research Unbundling: Transparent Separation of Research and Execution Costs
Why ADVISORI for Research Unbundling
- Years of experience with MiFID II implementation projects at banks and asset managers
- Proven methodology for RPA setup and cost allocation
- Holistic approach from regulation through processes to IT implementation
- Demonstrable results in reducing compliance risks and research costs
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Regulatory Action Required
Since 2018, research costs must be separately disclosed and paid. Violations of unbundling obligations can result in supervisory measures. A structured implementation ensures compliance and creates operational clarity.
ADVISORI in Numbers
11+
Years of Experience
120+
Employees
520+
Projects
We guide financial institutions systematically through the implementation of MiFID II unbundling requirements — from initial assessment to operational implementation.
Our Approach:
Analysis of existing research payment structures and identification of regulatory gaps
Design of compliant structures for Research Payment Account or own-resource model
Building procurement governance processes and provider evaluation methodology
Implementation of research tracking, usage documentation and quality assessment
Training for front office, compliance and management with ongoing support
"Implementing MiFID II unbundling requirements was a significant organisational challenge for us as an asset manager. ADVISORI guided us from gap analysis through RPA setup to training our portfolio managers. The practice-oriented approach was particularly valuable — instead of theoretical concepts, we received immediately actionable processes."
Melanie Düring
Head of Risk Management
Our Services
We offer you tailored solutions for your digital transformation
Gap Analysis and Compliance Assessment
We analyse your existing research payment structures and assess conformity with MiFID II unbundling requirements. The result is a clear action plan with prioritised measures.
- Inventory of all research payment relationships and commission structures
- Regulatory gap analysis against MiFID II and delegated regulations
- Assessment of boundaries between reimbursable research and market information
- Prioritised action plan with timelines and responsibilities
Research Payment Account (RPA) — Setup and Management
We design and implement a regulatory-compliant Research Payment Account, including budget setting, disclosure obligations and quality assessment.
- RPA model design with budget calculation and client disclosure
- Setup of technical and organisational RPA infrastructure
- Regular quality and value-for-money assessment of paid research
- Transparent documentation and reporting to clients and regulators
Procurement Governance and Vendor Management
Building structured procurement processes for external financial research — from provider selection through pricing to ongoing evaluation.
- Development of research valuation models with quality criteria and pricing tiers
- Establishment of governance structures for research procurement decisions
- Processes for handling unsolicited research
- Periodic provider reviews and contract management
Research Tracking and Usage Documentation
Implementation of systems for recording, evaluating and documenting research usage — a core requirement of MiFID II unbundling rules.
- Selection and implementation of suitable tracking tools and systems
- Recording research usage by analyst, provider and topic
- Linking research usage to investment decisions
- Audit-proof documentation for regulatory examinations
Cost Allocation and Budget Management
Transparent allocation of research costs across funds and mandates — with clear methods and disclosure to clients.
- Development of allocation keys for different funds and mandates
- Annual budget setting and calibration for research spending
- Transparent disclosure of research costs to institutional clients
- Cost benchmarking against market standards and peer comparisons
Training, Change Management and Ongoing Support
Supporting organisational change — from front office awareness to sustainable embedding of unbundling processes in daily operations.
- Training programmes for portfolio managers, analysts and compliance staff
- Development of internal policies and process documentation
- Support during regulatory examinations and enquiries
- Ongoing regulatory monitoring and adaptation to new requirements
Our Competencies in MiFID
Choose the area that fits your requirements
Algorithmic Trading & HFT: MiFID II Compliance | ADVISORI
MiFID Algorithmic Trading defines comprehensive compliance standards for automated trading systems and ensures solid risk control while maintaining market integrity. As a leading AI consultancy, we develop tailored RegTech solutions for intelligent Pre-Trade Controls, automated Risk Management systems, and strategic Algorithmic Trading optimization with complete IP protection.
ESMA Guidelines under MiFID II: Suitability, Product Governance & Remuneration
MiFID ESMA Guidelines define uniform supervisory standards and ensure harmonized application of MiFID provisions across EU member states. As a leading AI consultancy, we develop customized RegTech solutions for intelligent ESMA Guidelines implementation, automated Supervisory Convergence, and strategic compliance optimization with complete IP protection.
MiFID Best Execution – Ensuring Optimal Order Execution Quality
The MiFID II best execution obligation requires investment firms to take all sufficient steps to obtain the best possible result for clients when executing orders. We help you develop a robust execution policy, analyse and select appropriate execution venues, and establish transparent monitoring and reporting processes – from RTS 27/28 compliance to ongoing quality assurance.
MiFID Conduct of Business Rules: Suitability, Cost Transparency & Product Governance
MiFID II conduct of business rules establish the investor protection framework for investment firms across the EU. They define how firms must classify clients, provide investment advice, disclose costs and govern products — from suitability assessments through cost transparency to product governance. ADVISORI supports firms in the practical, auditable implementation of these obligations.
MiFID Data Reporting Services – APA, CTP & ARM Compliance Advisory
Data Reporting Services Providers (DRSPs) form the backbone of financial market transparency under MiFID II and MiFIR. As APAs, CTPs or ARMs, they ensure that transaction reports under Art. 26 MiFIR are submitted to competent authorities on time and accurately. ADVISORI advises financial institutions on selecting, connecting and maintaining compliance with these services – including the new requirements from the MiFIR Review 2026.
MiFID II Compliance Framework: Securities Compliance & Regulatory Advisory | ADVISORI
MiFID II Compliance Framework Implementation requires precise integration of ESMA Guidelines with national supervisory requirements and comprehensive Client Protection. As a leading AI consultancy, we develop customized RegTech solutions for intelligent MiFID II compliance, automated investment services monitoring and strategic market advantages in the European investment services environment with complete IP protection.
MiFID II Implementation in Germany: WpHG, 2nd FiMaNoG and BaFin Supervision
MiFID German Implementation requires precise transposition of European directives into German supervisory law with specific BaFin requirements and WpHG integration. As a leading AI consultancy, we develop tailored RegTech solutions for intelligent BaFin compliance, automated WpHG monitoring and strategic German MiFID optimization with complete IP protection.
MiFID II Implementation: Gap Analysis, Project Management & Compliance Framework
Implementing MiFID II requires a structured gap analysis, clear project governance and the integration of compliance requirements into processes, systems and governance structures. ADVISORI guides your implementation project from initial assessment to an operational compliance framework.
MiFID II Investor Protection: Client Categorisation, Inducements & PRIIPs Compliance
MiFID II establishes binding protection standards for all investor categories. We support financial institutions in implementing client categorisation, inducement rules, PRIIPs key information documents, information duties and complaints handling – practical and regulatory-compliant.
MiFID II Position Limits for Commodity Derivatives | ADVISORI
Position limits under Article 57 MiFID II cap the maximum net position in commodity derivatives, aiming to prevent market abuse and ensure orderly price formation. ADVISORI supports financial institutions and trading firms in the compliant implementation of position limit requirements — from initial assessment through ongoing position management to regulatory reporting.
MiFID II Readiness
MiFID II and the upcoming MiFIR review present financial institutions with far-reaching compliance challenges. Our readiness assessment systematically identifies gaps across investor protection, transparency and market infrastructure – and develops a prioritised roadmap for your sustainable compliance.
MiFID III / MiFIR II: Key Changes, Timeline & Compliance 2025 | ADVISORI
MiFID III Updates & Changes require strategic adaptation to significant ESMA developments with Digital Finance integration, Crypto Assets regulation, and ESG compliance harmonization. As a leading AI consultancy, we develop tailored RegTech solutions for intelligent MiFID III transformation, automated regulatory adaptation, and strategic market advantages in the evolved European investment services environment with complete IP protection.
MiFID Market Data Costs: Transparency & Reasonable Commercial Basis – Advisory | ADVISORI
MiFID Market Data Costs form the foundation of transparent cost structures and ensure comprehensive cost control through precise data cost analysis and regulatory transparency. As a leading AI consultancy, we develop customized RegTech solutions for intelligent cost management automation, optimized vendor relationships, and strategic Market Data Cost excellence with complete IP protection.
MiFID Market Structure: Regulated Markets, MTF & OTF Explained
MiFID Market Structure defines the architecture of modern financial markets and ensures optimal market transparency through structured Trading Venue regulation and systematic Best execution requirements. As a leading AI consultancy, we develop customized RegTech solutions for intelligent market structure automation, optimized Trading Venue compliance, and strategic Market Structure excellence with complete IP protection.
MiFID Ongoing Compliance
Ensure your institution's long-term compliance with complex MiFID requirements through our comprehensive ongoing compliance approach. We implement solid governance structures, automated monitoring mechanisms, and proactive adaptation processes that guarantee continuous compliance and minimize regulatory risks.
Frequently Asked Questions about MiFID II Research Unbundling: Separating Research Costs from Execution
What does research unbundling under MiFID II mean?
Research unbundling under MiFID II means that investment firms must separately disclose and pay for financial research apart from trade execution costs. Since January 2018, research services may no longer be billed as part of bundled commissions. Instead, firms must either pay from their own resources or set up a Research Payment Account (RPA) through which costs are transparently passed on to clients. The goal is to avoid conflicts of interest and strengthen cost transparency for investors.
How does a Research Payment Account (RPA) work?
A Research Payment Account is a separate account through which investment firms handle payments for financial research. The RPA is funded from client funds, with the research budget set in advance and disclosed to clients. The firm must regularly assess whether the research paid for provides adequate value and transparently document the costs to clients. The RPA model ensures that research costs are no longer hidden within trading commissions.
Which financial institutions are affected by research unbundling?
MiFID II unbundling obligations apply to all investment firms providing portfolio management or other investment and ancillary services. This includes asset managers, portfolio managers, and certain pension fund managers based in the EU or EEA. Third-country firms serving clients in the EU must also observe the regulations when working with EU-regulated counterparties.
What are the most common challenges in implementing research unbundling?
The most common challenges include: correctly valuing and pricing research services, establishing functional procurement governance processes, handling unsolicited research, and maintaining ongoing documentation of research usage. Many institutions also struggle with distinguishing between reimbursable research and general market information, as well as integrating unbundling processes into existing IT systems.
How does ADVISORI help implement MiFID II research unbundling requirements?
ADVISORI guides institutions from the initial gap analysis through the design of compliant structures to operational implementation. This includes setting up a Research Payment Account, building procurement governance processes, implementing tracking systems for research usage, and training involved departments. Our consulting approach is practice-oriented and considers the individual processes and systems of each institution.
What penalties exist for violations of research unbundling obligations?
Violations of MiFID II unbundling obligations can result in supervisory measures including warnings, fines, and in severe cases, revocation of authorisation. BaFin and other national supervisory authorities monitor compliance as part of regular examinations. The FCA in the UK found that unbundling rules save investors an estimated
180 million pounds per year in costs — a sign of the practical relevance of these regulations.
What is the difference between research unbundling and research re-bundling?
Research unbundling refers to the obligation to separate research costs from trading commissions. Research re-bundling describes the recent regulatory development where supervisory authorities allow bundled payments again under certain conditions. The EU Listing Act (Directive 2024/2811), which must be transposed into national law by June 2026, removes the market capitalisation threshold and generally allows bundled payments again — subject to transparency and quality requirements. In the UK, the FCA is also reviewing a relaxation of unbundling rules.
What does the EU Listing Act 2024 change about research unbundling?
The EU Listing Act (Directive 2024/2811) allows bundled payments for research and execution services again from June
2026 — regardless of the issuer's market capitalisation. Firms must inform clients about the payment method, establish a research payment policy, enter remuneration agreements with providers, annually assess quality, and document total costs. The aim is to correct the negative impacts of strict unbundling on analyst coverage — particularly for smaller issuers.
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