A complete, modular compliance manual template covering all MiFID II obligations for Dutch investment firms. Customisable per firm type and licence scope — from full-service investment firms to execution-only brokers.
Built from practical implementation experience across multiple investment firms, this manual gives you a professional-grade compliance framework that would typically cost €30K+ in advisory fees to develop from scratch.
30-minute onboarding call included. Questions? Get in touch.
Every Dutch investment firm needs a compliance manual. AFM expects it, your compliance officer needs it, and your board should be able to point to it during supervisory reviews. Yet most firms either work with an outdated manual inherited from a previous compliance officer, or pay €30K–€50K to a law firm to draft one from scratch.
This template manual sits in between: a professionally structured, comprehensive framework that covers all MiFID II obligations relevant to Dutch investment firms, designed to be customised to your specific licence scope, activities, and organisational structure.
Modular chapters covering scope and definitions, governance and organisation, client categorisation, suitability and appropriateness, product governance, best execution, order handling, conflicts of interest, inducements, reporting obligations, and record keeping.
Standalone policy documents for each major MiFID II obligation. Ready to be adopted by your board and referenced in your compliance manual. Includes version control and approval tracking.
Visual decision tree and process documentation for classifying clients as retail, professional, or eligible counterparty. Includes opt-up and opt-down procedures with required documentation checklists.
Templates for both manufacturer and distributor obligations. Target market assessment forms, product approval procedures, distribution strategy templates, and periodic review frameworks.
Execution policy template, venue selection criteria, monitoring methodology, and reporting templates. Covers both RTS 27 and RTS 28 obligations with practical implementation guidance.
Structured checklist for the mandatory annual compliance review. Maps each review area to specific MiFID II articles and AFM guidance, with evidence requirements and finding templates.
Template for identifying, assessing, and managing conflicts of interest. Includes a conflict register, assessment methodology, and disclosure templates for situations where conflicts cannot be prevented.
Assessment templates aligned with ESMA's guidelines on MiFID II knowledge and competence requirements. Includes role-based competence matrices and annual assessment forms.
This manual is designed for Dutch-licensed investment firms that hold an AFM licence under Section 2:96 Wft (or are in the process of obtaining one). It covers the full spectrum of MiFID II obligations and can be scaled to match your firm's activities — whether you provide investment advice, portfolio management, execution services, or operate as a broker-dealer.
It is particularly valuable for firms that are setting up compliance infrastructure for the first time, replacing an outdated manual, or preparing for an AFM thematic review or on-site inspection.
Fully. Every chapter includes guidance notes explaining which sections apply to which firm types and licence scopes. Sections that don't apply to your activities can be marked as "not applicable" with a brief rationale — which is itself good practice for AFM reviews.
Yes. The manual references both the EU-level MiFID II/MiFIR framework and the Dutch implementation (Wft, Bgfo, Nadere regeling gedragstoezicht financiele ondernemingen). AFM-specific guidance and enforcement priorities are incorporated throughout.
The main manual and all policy templates are in Word (.docx) for easy editing. The decision tree and assessment templates are in Excel (.xlsx). All documents include Diletti branding which can be replaced with your own.
Absolutely. We offer a dedicated MiFID II Essentials workshop for compliance teams, as well as bespoke advisory engagements to help you customise and embed the manual in your operations. Get in touch to discuss.
Yes. Purchasers receive free updates for 12 months. Significant regulatory changes (e.g., MiFID II/MiFIR review outcomes, new AFM guidance) are incorporated and communicated via email.
Interactive preview of the assessment templates. Each component is provided as an editable Excel workbook with pre-built formulas and compliance checklists.
| Step | Question / Criterion | Retail | Professional (per se) | Professional (opt-up) | Eligible Counterparty | Legal Reference | Documentation Required |
|---|---|---|---|---|---|---|---|
| 1 | Is the client a legal entity? | If natural person → likely retail | Check per-se criteria (Art. 4(1)(10) MiFID II) | N/A at this step | Only if legal entity | Art. 4(1)(10) MiFID II | Entity documentation / ID |
| 2 | Does the entity meet per-se professional criteria? | Does not meet criteria | Yes: credit institution, investment firm, insurance company, UCITS, pension fund, commodity dealer, other institutional investor | Not yet applicable | Check Art. 30 MiFID II list | Art. 4(1)(10), Annex II MiFID II | Regulatory licence / registration proof |
| 3 | Quantitative test (opt-up) — meets 2 of 3? | Does not meet 2 of 3 | Already classified | Balance sheet ≥ €20M; Net turnover ≥ €40M; Own funds ≥ €2M | Already classified | Annex II, Section II MiFID II | Audited financial statements |
| 4 | Qualitative test — adequate expertise? | Standard retail protections apply | Already classified | Assessment of experience, knowledge, and understanding of risks | Already classified | Annex II, Section II MiFID II | Competence assessment form |
| 5 | Client informed and written agreement obtained? | N/A | Inform of protections foregone | Written request + written warning + written confirmation of understanding | Inform of protections foregone | Art. 24(2) MiFID II | Signed categorisation letter |
| 6 | Opt-down request received? | N/A — already retail | Client may request retail treatment | Client may request retail treatment | Client may request professional or retail | Art. 30(2) MiFID II | Written opt-down request |
| 7 | Annual reassessment of categorisation | Confirm retail status still appropriate | Verify criteria still met | Re-test quantitative + qualitative criteria | Confirm ECP criteria | ESMA Q&A on Investor Protection §10 | Annual review record |
| 8 | Record retention (5 years min) | All categorisation docs archived | All categorisation docs archived | Opt-up file incl. test results archived | All categorisation docs archived | Art. 72 CDR (MiFID II) | Archival confirmation |
We use strictly necessary cookies to run this site. With your permission we also set statistics cookies (Google Analytics) and marketing cookies (Calendly scheduling). You can change this choice anytime via the footer. See our privacy statement and cookie statement.