Firms that will be affected by the revised Markets in Financial Instruments Directive (MiFID 2) are probably tired of hearing exhortations from their regulators and advisers to start planning for MiFID 2 implementation. Everyone breathed a sigh of relief when the implementation date was delayed by a year, although there were stark warnings that the delay was because an extra year's preparation time was needed.
While firms had a reason to relax for a few months, maybe, while the European Commission and the European Securities and Markets Authority (ESMA) progressed level 2 legislation and technical standards that would provide more certainty as to the impact of the changes, there is no longer any leeway for relaxation. The changes (well, almost all the changes) will take effect on 3 January 2018.
In the UK, changes to legislation are nearly finalised, changes to regulatory requirements are under consultation, and the Financial Conduct Authority (FCA) has now issued its guide to applications and notifications and opened its application window. Firms that have not made complete relevant applications by the beginning of July risk not having the right permissions in place come 2018.