MiFID Compliance Function Assessment Checklist

In May 2026, the Central Bank of Ireland (the “CBI”) published the outcome of a thematic assessment of the compliance function conducted across a cohort of MiFID Investment Firms, with the key objectives of assessing firms’ adherence to the compliance function requirements set out in Article 22 of the MiFID II Delegated Regulation (the “Delegated Regulation”) and the related ESMA Guidelines (the “Thematic Assessment”).

Weaknesses were identified that require remediation, including in the areas of succession planning and contingency arrangements, compliance-led training programmes, the effectiveness of compliance monitoring programmes, and the quality of board and committee minutes in reflecting substantive discussion and challenge of compliance-related matters.

The CBI expects all MiFID Investment Firms to consider the contents of the report and conduct a comprehensive self-assessment of their compliance function against the findings outlined in it and the requirements set out in Article 22 of the Delegated Regulation and the related ESMA Guidelines. Firms are also reminded of the revised Consumer Protection Code and the related Guidance on Securing Customers’ Interests and the Guidance on Protecting Consumers in Vulnerable Circumstances and should consider how their compliance function can support embedding these standards in their business.

Where gaps or weaknesses are identified, firms should develop and implement actions to address these in a proactive and timely manner; and the CBI requires the report to be discussed at the next board meeting, with the discussion recorded in the meeting minutes.

This checklist has been prepared to assist MiFID firms in carrying out that self-assessment in a structured and practical way. It includes the requirements of Article 22 of the Delegated Regulation and the expectations of the CBI from the Thematic Assessment.

Access the MiFID compliance function assessment checklist here.