Business Rules - MiFID II Compliance (EN)

Core business rules of the MiFID II compliance domain for fintech platforms. Code BR-NNN, priority High/Medium/Low. Each rule describes the compliance process, is technology-independent, and does NOT constitute an operational recommendation.

> Financial disclaimer: This section is for descriptive and informational purposes only. It does not constitute financial advice or an investment recommendation. Always consult a qualified professional (professionista abilitato) before making operational decisions. Reference legal framework: MiFID II Dir. 2014/65/EU; MiFIR Reg. (EU) 600/2014 (2014).

---

BR-001 - Mandatory client categorisation before service provision

Code: BR-001 Name: Preliminary client categorisation Description: Every ClienteInvestimento (investment client) must be classified into one of three categories (Retail, Professional, Eligible Counterparty) before any investment service is provided. The category determines the applicable protection level and disclosure obligations. Rationale: Protection is graduated by category; serving an uncategorised client breaches conduct-of-business obligations. Priority: High Actors: Compliance Officer, Onboarding System Traceability: MiFID II Dir. 2014/65/EU Art. 24-25; Annex II; glossary Client Categorisation.

BR-002 - Suitability assessment for advice and portfolio management

Code: BR-002 Name: Mandatory suitability Description: For investment advice and portfolio management, a ValutazioneAdeguatezza (suitability assessment) must be recorded documenting the client's knowledge and experience, financial situation and investment objectives. Absence of the assessment prevents service provision. Rationale: The compliance process requires the provider not to operate without the documentary basis required by the rule. Priority: High Actors: Compliance Officer, Onboarding System Traceability: MiFID II Dir. 2014/65/EU Art. 25(2); ESMA Suitability Guidelines.

BR-003 - Appropriateness assessment for non-advised services

Code: BR-003 Name: Appropriateness for complex products Description: For services other than advice, when the product is complex, a ValutazioneAppropriatezza (appropriateness assessment) on the client's knowledge and experience must be recorded. A negative assessment requires a documented warning; non-complex instruments in execution-only are exempt. Rationale: The process distinguishes complex from non-complex products to apply the correct informational safeguard. Priority: High Actors: Compliance Officer Traceability: MiFID II Dir. 2014/65/EU Art. 25(3)-(4).

BR-004 - Best execution and documented execution policy

Code: BR-004 Name: Best Execution Description: Every OrdineFinanziario (financial order) must be executed under a documented PoliticaEsecuzione (execution policy) pursuing the best possible result for the client considering price, costs, speed, likelihood of execution and settlement. Execution venues used must be enumerated in the policy. Rationale: Best execution is a verifiable process obligation, not a guaranteed outcome. Priority: High Actors: Order Management, Compliance Officer Traceability: MiFID II Dir. 2014/65/EU Art. 27; RTS 27/RTS 28.

BR-005 - Complete and timely transaction reporting

Code: BR-005 Name: Transaction Reporting RTS 22 Description: Each transaction in reportable instruments generates a ReportTransazione (transaction report) with RTS 22 fields (including counterparty LEI) to be transmitted to the Competent Authority by the following business day (T+1). An incomplete or late report is a process breach. Rationale: Reporting feeds market surveillance; field completeness is verifiable at process level. Priority: High Actors: Reporting System, ARM Traceability: MiFIR Reg. (EU) 600/2014 Art. 26; RTS 22.

BR-006 - LEI identification for legal entities

Code: BR-006 Name: Mandatory LEI Description: No transaction on behalf of a legal entity may be executed or reported without a valid, active counterparty LEI ("no LEI, no trade"). A lapsed LEI blocks execution. Rationale: Unambiguous counterparty identification is a structural prerequisite of reporting. Priority: High Actors: Order Management, Reporting System Traceability: MiFIR Reg. (EU) 600/2014 Art. 26(6); RTS 22.

BR-007 - Product governance and target market

Code: BR-007 Name: Product Governance Description: Every distributed StrumentoFinanziario (financial instrument) must have a defined target market (positive and negative) consistent with the client category to which it is offered. Distribution outside the target market must be documented and justified. Rationale: Governance ensures product-client consistency along the distribution chain. Priority: Medium Actors: Compliance Officer Traceability: MiFID II Dir. 2014/65/EU Art. 16(3), 24(2).

BR-008 - Pre- and post-trade transparency

Code: BR-008 Name: Transparency obligations Description: Quotes and transactions on trading venues and for systematic internalisers are subject to pre- and post-trade transparency obligations, save for applicable waivers (e.g. LIS, reference price). Post-trade publication occurs via APA within the prescribed timeframes. Rationale: Transparency feeds price formation; exemptions are exhaustive and documented. Priority: Medium Actors: Trading Venue, SI, APA Traceability: MiFIR Reg. (EU) 600/2014 Art. 3-15.