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ARTICLE · 11 SEPTEMBER 2026

Changes To MiFID Order Execution Policies

Dillon Eustace
Dillon Eustace
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Dillon Eustace

Dillon Eustace

Dillon Eustace is one of Ireland’s leading law firms focusing on asset management and investment...

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Commission Delegated Regulation (EU) 2026/825 introduces sweeping changes to MiFID order execution requirements, shifting from public disclosure to robust internal governance. Investment firms face enhanced obligations around execution venue selection, continuous quality monitoring using objective market data, and comprehensive documentation of routing decisions. How will firms adapt their execution frameworks to meet these data-driven standards by the February 2028 deadline?

IrelandFinance and Banking
Keith Waine
Keith Waine
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For further information on any of the issues discussed in this publication please contact the related contact(s) on this page.

Key Takeaways

  • New MiFID Order Execution Rules

    Commission Delegated Regulation (EU) 2026/825 introduces a stronger focus on best execution governance, requiring investment firms to maintain detailed Order Execution Policies (OEPs), execution venue registers, and auditable decision-making processes.

  • Best Execution Monitoring Becomes More Data-Driven

    Under the new MiFID best execution framework, firms must continuously assess execution quality using objective market data (including Consolidated Tape Provider (CTP) data where available) and be able to demonstrate that their execution arrangements operate to consistently obtain the best possible result for clients taking into account the applicable execution factors.

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