Press Release

PIMFA Expresses Concerns about the Complexity of the MiFID II Costs & Charges

Tuesday 17th September 2019

In their recent response to the European Securities and Markets Authority’s (ESMA) Call for Evidence on Inducements and Costs and Charges Disclosure Requirements under Markets in Financial Instruments Directive (MIFID) II, PIMFA has outlined their concerns about the complexity of these disclosure requirements and the burdens they place on firms seeking to comply with those requirements.

Although ESMA suggests that certain difficulties identified with the current regime can best be addressed through further, more detailed rules and mandated presentation formats.

PIMFA – the trade association for investment managers and financial advisers – has responded saying that MiFID II should not provide any more detailed rules governing the timing, format and presentation of these disclosures at this current time as well as loading further significant costs on firms. They argue, this would only serve to further confuse consumers, many of whom are less than clear about what the new MIFID II disclosures mean. Instead, if amendments to the MiFID II costs and charges regime are required, they should be subject to a review process that requires detailed consultation, cost-benefit analysis and consumer testing, while also taking into consideration the industry, consumer and supervisory experience of the operation of the current regime to date.

Sarah McGuffick, Lead Regulatory Policy Adviser at PIMFA said;

“We have made it clear that, if there was to be any hope of MiFID II being applied consistently across the industry, the regulators would need to provide unambiguous and detailed provisions on which firms could base both systems specifications/development. This in turn could result in the necessary changes to in-house processes and procedures. The fact that this did not happen has resulted not only in firms incurring huge costs in interpreting and applying regulation but also in their diverting resources away from their most important function, namely the day-to-day servicing of their clients’ needs and wishes.”

The full consultation response is available to read on the PIMFA website here.





About PIMFA – the Personal Investment Management & Financial Advice Association

  • PIMFA is the leading trade association for firms that provide investment management and financial advice to everyone from individuals and families to charities, pension funds, trusts and companies.
  • PIMFA represents both full and associate member firms. Full members provide a range of financial solutions including financial advice, portfolio management, as well as investment and execution services. They assist everyone from individuals and families, to charities and pension funds, all the way to trusts and companies.  Associate members provide professional services to the PIMFA community.
  • PIMFAleads the debate on policy and regulatory recommendations to ensure that the UK remains a global centre of excellence in the wealth management, investment advice and financial planning arena.  Our mission is to create an optimal operating environment so that its member firms can focus on delivering the best service to clients, providing responsible stewardship for their long-term savings and investments.
  • PIMFA was created in 2017 as the outcome of a merger between the Association of Professional Financial Advisers (APFA) and the Wealth Management Association (WMA) with a history as a trade association going back for 28 years – read more.
  • Further information can be found at
  • To become a member of PIMFA for access to training, benefits and discounts, please visit or contact us directly at


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