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21. The Permission Was Always There: MiFIR Direct Reporting in 2026

CP25/32 has now confirmed that the three route model (direct, ARM and trading venue) is preserved.

/ Summary

This session is the fully loaded business case for moving direct. We work through the legal basis under Article 26(7), the cost reality of ARMs (£17k up to £753k a year depending on tier, with annual escalators of 3% to 5% and back reporting surcharges of 150% to 200%) and the total cost of ownership comparison across ARM, internal build and RegTech routes over one, three and five years, showing 68% Year 1 savings against an ARM and 92% against an internal build. We address head on the five operational challenges of going direct (NCA accountability, multi jurisdiction infrastructure, data quality, exception management, regulatory intelligence) and how each is solved by a RegTech partner that supports 14 EU and UK NCAs. Includes the architecture overview, a live demonstration against real regulatory data and a six step action roadmap with an 8 to 12 week implementation timeline. The decisive senior leadership read on whether to renew, insource or replace.

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