Discussion Paper on MiFID II investor protection topics linked to digitalisation

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Digital Finance and Innovation
Investor protection
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Responding to this paper

ESMA welcomes comments on this Discussion Paper on digitalisation and in particular on the specific questions set out in this paper. 

All comments can be submitted online on this page.

Please note that responses must reach us by 14 March 2024. Comments submitted after this deadline, or submitted via other means may not be processed. 

Comments are most helpful if they:

  1. Respond to the question posed;
  2. Indicate the specific question or point to which a comment relates;
  3. Are supported by a clear rationale;
  4. Provide evidence to support the views expressed or rationale proposed.

It is important to note that although you may not be able to respond to every single question, ESMA would encourage partial responses from stakeholders on those questions that they believe are most relevant to them. 

All contributions received will be published following the close of the discussion period unless you request otherwise by ticking the relevant box in the online form. Please note that a request to access a confidential response may be submitted in accordance with ESMA’s rules on public access to documents. We may consult you if we would receive such request. 

Data protection 

Information on data protection can be found under the heading Legal Notice and Data Protection.

Who should read this paper?

This paper is primarily of interest to competent authorities, firms that are subject to Directive 2014/65/EU on Markets in Financial Instruments (MiFID II) and their clients. Due to its focus on investor protection issues, this paper is therefore addressed to investor and consumer organisations; to investment firms and credit institutions providing investment services and activities; to UCITS management companies and external Alternative Investment Fund Managers (AIFMs) when providing investment services; and to any relevant trade association. The paper may also be of interest to firms that provide the digital engagement practices described in this paper. 

Activity Institution Download
Others AMAFI
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Banking European Savings and Retail Banking Group (ESBG)
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Investment Services SSMA
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Asset Management France Invest
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Banking Italian Banking Association
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Banking Austrian Federal Economic Chamber, Division Bank an Insurance
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Others Finance Finland
  • 204663
Investment Services BVI Bundesverband Investment und Asset Management e.V.
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Others Finance Denmark
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Others CNCEF PATRIMOINE
  • 204680
Banking Association of German Banks (Bundesverband deutscher Banken e.V.)
  • 204692
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Banking Commerzbank AG
  • 204704
Others ANASF
  • 204706
Others BIPAR (European Federation of Insurance Intermediaries)
  • 204718
Banking European Association of Cooperative Banks
  • 204723
Asset Management AFG
  • 204726
Issuers BundBundesverband für strukturierte Wertpapiere e.V. (BSW)
  • 204729
Investment Services ASSORETI
  • 204738
Banking Fédération Bancaire Française
  • 204746
Asset Management Dutch Fund and Asset Management Association (DUFAS)
  • 204747
Robinhood Markets, Inc.
  • 205205