The Markets in Financial Instruments Directive (MiFID II) has harmonised wholesale markets regulation across European Union member states. However, once the United Kingdom left the EU, the triggering of the Withdrawal Act (EUWA) saw the transposition of EU law into UK domestic law, MiFID II included. 

Since the end of the Brexit transition period, the UK has made multiple changes to EU MiFID II requirements as the UK Government and the Financial Conduct Authority (FCA) have sought to address perceived deficiencies in the transposed UK MiFID II regime, such as the administrative reporting burden for investment firms. These changes also address the UK’s post-Brexit priority of promoting global competition in the UK market at the cost of regulatory divergence with the EU.

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