Date: 19th May 2020


General comment

The review of the MiFID II framework is timely and should be coordinated with the other ongoing actions and policy areas, i.e. PRIIPs and the work done in the Forum on the Future of the Capital Markets Union. In addition, to ensure a level playing field, the European Commission should also adopt a coordinated approach concerning the insurance market, in particular insurance-based
investment products.


The MiFID2 review must undo the severe damages generated by the SI/OTC regimes and bring back equity trading in the EU on “lit” markets, at the very least “retail” trading.

Advice and

BETTER FINANCE supports a complete ban on inducements; as a distant second best asks to establish a level playing field for closed architecture distribution, for independent advice and for execution only investments. The EU authorities must also at least ensure a level playing field with insurance-based investment products (IBIPs).

Qualified investors

BETTER FINANCE supports a better access for qualified non-professional investors to exchange-traded stocks, bonds and ETFs.

SME research

BETTER FINANCE supports the development of SME research databases, supervised by ESMA, which should be publicly available and receive the necessary support in order to stimulate research for SMEs.

Toxic products

BETTER FINANCE supports the development of a definition for toxic products, and for clarifying ESMA intervention powers on such toxic products.

Robo-advice and

FinTech and automated investment platforms have the potential to increase transparency and cost efficiency in financial services, increase competition and financial inclusion