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Reinforcing investor protection: new edition of ABBL’s MiFID II guidelines

Published on 23 June 2025

On 18 June 2025, the ABBL had the pleasure of hosting an exclusive launch event to mark the publication of the revised Industry Guidelines on MiFID II - Investor Protection. This milestone reflects over a year of joint efforts by a dedicated group of professionals across Luxembourg’s financial sector, working under the coordination of the ABBL. The guidelines, now in their second edition, provide non-binding but practical insights into the application of MiFID II, with a dedicated focus on investor protection. Their primary objective is to support ABBL members in navigating regulatory expectations while keeping clients’ interests firmly at the centre.

Summary

    A shared achievement by the financial industry

    This updated edition would not have been possible without the unwavering commitment of the ABBL MiFID Guidelines Taskforce. Representatives from banks, law firms, consultancy firms and other institutions worked hand in hand to reflect regulatory developments, market practices and supervisory expectations.

    Their collective expertise ensured a comprehensive and pragmatic interpretation of MiFID II, covering essential topics such as:

    • suitability and appropriateness assessments
    • transparency and disclosure of costs
    • product governance and investor profiling
    • client reporting and communications
    • ESG preferences and sustainability-related measures

    The ABBL wishes to thank all members who contributed to the drafting process, and warmly acknowledges the role of the following experts whose involvement was especially instrumental:

    • Benjamin Accadia, Partner, EY Business Advisory Services
    • Sébastien Leleu, Partner Advisory | Risk & Regulatory, KPMG Luxembourg

    Their guidance, motivation and attention to regulatory and operational detail brought valuable structure to the process from start to finish.

    The ABBL’s coordinating role in regulatory dialogue

    Beyond the regulatory content, this publication illustrates how ABBL plays a pivotal role in enabling collective intelligence. As a platform for dialogue, exchange and synthesis, ABBL ensures that the voice of its members is channelled into usable, practical outputs that support sound and compliant banking operations.

    For industry guidelines to remain truly valuable, they must continually evolve – staying practical, relevant, and aligned with both regulatory expectations and market needs.

    Marilyn Rinck

    Senior Adviser – Financial Markets

    A practical tool, reserved for ABBL members

    While the guidelines are non-binding and do not constitute legal advice, they serve as a useful reference for applying MiFID II in Luxembourg. They reflect:

    • the Luxembourg transposition of MiFID II
    • relevant Level 2 and Level 3 measures from the European Commission and ESMA
    • CSSF guidance and positions

    ABBL members are encouraged to share the guidelines internally with relevant teams, including legal, compliance and client-facing functions.

    Thank you to all contributors

    The ABBL extends its warmest thanks to all members and experts who took part in the drafting process of the updated MiFID II guidelines. Their time, insights and commitment were key to producing a resource that reflects both regulatory expectations and operational realities.

    Members of the ABBL MiFID Guidelines Taskforce
    Benjamin Accadia (Ernst & Young SA) | Virginie Etienne (Bank Julius Baer Europe SA) | Julien Froumouth (Spuerkeess) | Tim Geyens (Bank Pictet & Cie (Europe) AG, Luxembourg Branch) | Glenn Meyer (Arendt & Medernach SA) | Manuel Juan Juan (Bank Julius Baer Europe SA) | Cécile Liégeois (PwC Luxembourg) | Sébastien Leleu (KPMG Luxembourg) | Gonçalo Melo de Sampaio (Linklaters LLP) | Glenn Meyer (Arendt & Medernach SA) | Tiago Nogueira (Elvinger Hoss Prussen SA) | Benoît Sauvage (Svenska Handelsbanken AB (Publ), Luxembourg Branch) | Carole Schmidt (Allen Overy Shearman Sterling SCS) | Sebastian Schieck (Deloitte General Services SARL) | Frédéric Schmit (Arendt & Medernach SA) | Carole Schmidt (Allen Overy Shearman Sterling SCS) | Beate Twellmeyer (Deloitte General Services SARL) | Céline Troquet (Banque Internationale à Luxembourg SA) | Isabelle Willequet (PwC Luxembourg) | Fabienne Wirtz (AIQU Tax SARL) | Marie Zavoralova (UniCredit International Bank (Luxembourg) SA) | Béatrice Debarnot (Banque Raiffeisen SC)

    Marilyn Rinck

    Senior Adviser – Financial Markets

    Published on 23 June 2025

    See all articles by Marilyn Rinck