ESG: MiFID Suitability Assessment – Are firms and clients speaking the same language?

8th April 2022

On 21 April 2021, the European Commission adopted a new Delegated Regulation (EU) 2021/1253 amending Delegated Directive (EU) 2017/565 (the “MiFID II Delegated Regulation”).

Further to this amendment, investment firms authorised under Directive 2014/65/EU on markets in financial instruments (“MiFID II”) are required to incorporate ESG considerations on the suitability assessment they perform, when offering certain products or services to their client. This assessment must now be made with reference to any sustainability preference expressed by the client.

In summary, the amendments force investment firms to align their thinking about Environmental Social and Governance criteria (“ESG”) with the client’s perspective around ESG and sustainability. In other words: are firms and clients on the same page?

Elisa Forletta-Fehrenberg, Head of ESG and Sarah Noville, Senior Associate, explore what impact the amendments to the MiFID suitability assessments mean in practice. 

Access the whitepaper here


Elisa Forletta-Fehrenberg


Sarah Noville