MiFIR Review 2026: No More “Wait and See” for EU Investment Firms

As of March 2026, EU rules have shifted from transition to full enforcement.

For CEOs of investment firms and neobrokers, the “grandfathering” grace periods are over.

AIFMD II targeted fund governance and delegation. The MiFIR Review 2026 focuses on the market’s basics. It covers how trades are executed. It also covers how data is reported. It aims to ensure retail investors get good value for their money. Many in the market refer to it as MiFID III.

The MiFIR Review 2026 introduces four major structural changes that will reshape revenue models, data infrastructure, and product governance.

Below is a strategic briefing for the June 30, 2026 pivot.

1. The PFOF Ban: The End of “Zero-Commission” Trading

A major change takes effect on June 30, 2026.On that date, the temporary exemption for certain member states ends.This includes Germany, under Article 39a of MiFIR.

What the rule requires  

Investment firms may not accept any fee or commission from third parties for executing retail orders on specific venues.

What this changes  

This ends payment for order flow (PFOF). PFOF is a business model. It has long brought in about 30% of revenue for leading neobrokers.

What firms will do next  

Firms must replace that revenue by using subscription pricing, like a monthly flat fee. They can also internalize order flow through their own multilateral trading facilities (MTFs).

2. MiFIR Consolidated Tape 2026: Real-Time Data Becomes the Standard

Fragmented market data is on the way out. By the end of 2026, the EU market will start using one shared view of liquidity. EuroCTP will cover equities. Ediphy will cover bonds.

No artificial delays  

MiFIR requires firms to send data to the tape provider as close to real time as technically possible.

Clock synchronization  

Starting March 2026, firms must meet microsecond-level timestamp standards so trades can be sequenced accurately across the EU.

Why it matters  

This supports the EU’s “Savings and Investment Union.” It gives retail-focused firms access to high-quality market data on a reasonable commercial basis (RCB). This lowers barriers to entry.

3. DPE vs. SI: A Clearer Post-Trade Reporting Framework

One of the most practical outcomes of the MiFIR Review is that post-trade reporting no longer depends on SI status.

The DPE model  

Since February 2025, firms have been able to use designated publishing entity (DPE) status. A DPE can handle OTC trade reporting. It can do this without the added duties of SI status. These include pre-trade transparency and quoting rules.

The updated reporting hierarchy (“waterfall”)  

- If one party is a DPE and the other is not, the DPE reports.  

- If both parties are DPEs, the seller reports.

Asset-class specificity  

Unlike the UK’s entity-level approach, DPE registration in the EU applies by asset class. That means reporting workflows must be detailed and tightly controlled.

4. Value for Money (VfM): Costs Must Be Defensible, Not Just Disclosed

The Retail Investment Strategy (RIS) has reshaped product governance. Firms can’t simply disclose costs—they must justify them.

Supervisory benchmarks  

Firms must compare product costs and charges against peer groups and EU-wide benchmarks set by ESMA and EIOPA.

A proportionality test  

If a product greatly exceeds benchmarks without clear, data-backed value, firms must stop selling it to retail clients.

Expanded access to professional status  

To address these limits, the rules for “opt-in” professional clients are more flexible. The portfolio threshold drops to €250,000. Relevant education or training can also qualify a client.

Why Regulatory Orchestration Is Now Essential

The speed and scale of MiFIR Review 2026 data requirements make manual compliance unsustainable.

If you rely on spreadsheets for DPE status or periodic value-for-money reviews, you risk data drift. Data drift is the gap between what you report and what is happening.

At Dorhyan.eu, we don’t just advise. We help you operationalize compliance through regulatory orchestration—integrating live ESMA registers, automated reporting logic, and dynamic cost benchmarking directly into the trade lifecycle.

Final Thought: Compliance Is Becoming Market Infrastructure

MiFIR Review 2026 isn’t a routine update. It redesigns how European markets operate.

With PFOF ending, the consolidated tape will go live. Stronger value-for-money rules will also apply. Firms will compete by using accurate data. They will provide clear reporting. They will deliver better execution.

Is your firm ready for the June 30, 2026, PFOF deadline and the consolidated tape go-live?

The window to re-engineer your operating model is closing.