Design and implementation of your complete MiFID II compliance framework — from client-facing obligations to back-office reporting. Operational processes your team can actually run, not a binder of policies.
Built to withstand AFM supervisory review, by someone who has implemented it in practice.
Scoped to your licence and proportionate to your size.
Most Dutch investment firms built their MiFID II setup in 2017–2018 and have grown past it since. New desks, new instruments, new client segments — while the compliance framework stayed where it was. That gap surfaces at the worst possible moment: an AFM information request, a transaction reporting quality letter, or an onsite review.
We rebuild the framework around how your firm operates today. The full regulatory perimeter, translated into processes with owners, controls and evidence — so a supervisory review becomes a demonstration rather than a scramble.
RTS 22 field-level mapping, RTS 23 reference data, RTS 25 clock synchronisation. Reconciliation and data quality controls that catch errors before your ARM — and the AFM — do.
Execution policy, venue and broker review cycle, monitoring methodology and management information. Proportionate to your order flow, defensible in a review.
Categorisation logic, opt-up procedures, appropriateness and suitability workflows with the documentation trail the rules require.
Target market assessments, distributor information exchange and the periodic product review process — embedded in your product approval workflow.
Conflicts register, identification procedures, mitigation measures and the governance to keep it current instead of a one-off exercise.
Retention framework across communications and orders, plus a staff knowledge and competence programme that satisfies ESMA guidelines.
Weeks 1–2. Map your licence scope, services and instruments to the applicable MiFID II/MiFIR obligations. Agree priorities with compliance and the board.
Weeks 3–6. Test the current framework against the perimeter — documents, processes and evidence. Findings ranked by supervisory risk, not by page count.
Months 2–5. Close the gaps in priority order: processes, controls, registers, monitoring and management information. Working sessions with the people who will own each control.
Final month. Dry-run the framework: monitoring cycle executed, evidence produced, board reporting in place. Handover with training and a maintenance calendar.
Dutch-licensed investment firms, proprietary traders and trading venues that have outgrown their initial compliance setup — or are heading into an AFM licensing trajectory and need the framework built right the first time. Read our MiFID II framework guide for how we think about the perimeter.
If your priority is the prudential side — IFR/IFD, K-factors and DNB filings — see our DNB regulatory reporting service.
A full framework build typically runs 3–6 months depending on your licence scope and current maturity. A focused remediation — for example transaction reporting only — can be done in 6–8 weeks.
The AFM reviews operating effectiveness, not paperwork. A policy without monitoring evidence, clear ownership and demonstrable execution is a finding waiting to happen. We build the processes and controls behind the documents.
Yes. Many clients retain us for periodic compliance monitoring, best execution reviews or transaction reporting quality checks after the build. That is optional — everything we deliver is designed so your own team can run it.
We work for and with your compliance function, never around it. Your compliance officer keeps ownership; we bring the implementation capacity and regulatory depth that a one-person function rarely has time for.
The framework is built on the current MiFID II/MiFIR rulebook with the MiFIR Review changes tracked explicitly, so upcoming amendments land as controlled change requests rather than a rebuild.
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