Regulatory status checked: 10 August 2026.
The Council of the EU and the European Parliament reached a provisional political agreement on the Retail Investment Strategy on 18 December 2025. The package was still awaiting formal adoption and publication at the date of this review. Its provisions should therefore be described as agreed legislative changes rather than rules already in application.
The provisional agreement requires firms to identify and quantify the costs and charges borne by retail investors. Firms must then assess whether total costs and charges are justified and proportionate.
The agreed approach is not identical across every regulatory framework. It uses peer groupings for products covered by MiFID, UCITS and AIFMD, while products under the Insurance Distribution Directive are assessed with reference to supervisory benchmarks. Under the provisional agreement, a product whose costs and charges are not justified and proportionate should not be approved for sale.
The package also updates standardised product information. Costs, risks and expected returns are intended to become more visible and accessible in Key Information Documents. The relevant European supervisory authorities are expected to develop the updated templates.
For recommendations concerning diversified, non-complex and cost-efficient instruments, the provisional agreement provides for a simplified suitability process under which advisers would no longer assess the client’s knowledge and experience. The remaining suitability considerations continue to matter, including the client’s financial situation, objectives, capacity for loss and risk tolerance.
The provisional text strengthens the requirement for firms and advisers to act honestly, fairly and professionally in the client’s best interests. Where inducements are received, they must provide a tangible benefit to the client and be disclosed clearly and separately from other costs. Member States would remain able to introduce national inducement bans.
The package also addresses financial influencers and the responsibility of firms for marketing communications. Institutions using external promoters should therefore review governance, contractual arrangements and controls over public communications when the final requirements are published.
The exact commencement dates will run from publication of the final acts in the Official Journal. Institutions can begin mapping affected products, cost data, product-governance controls, KID processes and distribution arrangements, but final implementation should follow the adopted wording and subsequent technical standards.
Regulatory status checked: 10 August 2026. Regulation (EU) 2025/2075 requires in-scope transactions in transferable securities executed on EU trading venues
The financial-services advisory firm CMP is appointing Lene Hjortshøj as a new partner and opening an office in Aarhus to
