Buy-Side Research Under MiFID II: A Practical Guide for Investment Teams

What Counts as “Research” Under MiFID II: A Buy-Side Primer

MiFID II defines investment research broadly: material that provides information or suggests an investment strategy about financial instruments or issuers, and generally includes an opinion, rather than routine market commentary or marketing material. Buy-side teams need this definition clear before evaluating how a piece of content was funded and whether it can be legitimately consumed.

The European Central Bank’s briefing on MiFID II research rules, prepared with Commerzbank input in October 2017, remains a useful historical marker for how the market structure shifted once research got pulled out of trading commissions and into its own regulated category. Before MiFID II, research arrived bundled with execution, effectively “free” but invisibly priced into spreads and commissions. After MiFID II, research became a service with its own cost, its own paper trail, and its own set of rules governing who can pay for it and how.

Under Annex I, Section B(5) of MiFID II, investment research is formally categorized as an “ancillary service,” distinct from core investment services like execution or portfolio management. Recital 28 of the MiFID II Delegated Directive sets out the broader framing that commentary from Aston University researchers, published on SSRN, has used to explain why regulators drew such a sharp line between research and marketing collateral: research is meant to carry independent analytical value, not to promote a specific transaction or product.

That distinction matters operationally. A buy-side compliance officer reviewing incoming content from a broker has to ask whether it meets the research definition at all before asking whether it was paid for correctly. Get the classification wrong, and every downstream inducement analysis is built on sand.

How Research Is Funded: From Inducement Bans to Research Payment Accounts

MiFID II treats third-party research as a potential inducement unless it is paid for either directly from the firm’s own resources or through a properly structured Research Payment Account (RPA). Getting this funding mechanism wrong risks regulatory exposure, which is why most buy-side compliance teams treat it as a standing agenda item, not a one-time setup task.

Article 24(9a) of MiFID II and Article 13 of the MiFID II Delegated Directive, Commission Delegated Directive (EU) 2017/593, lay out the specific conditions research must meet to avoid inducement classification. ESMA’s Consultation Paper on Technical Advice on MiFID II DD Research, published October 2024, followed by its formal Technical Advice to the European Commission in April 2025, confirms these two provisions are still the operative test nearly a decade after MiFID II first took effect.

Latham & Watkins’ quick start guide on MiFID II research lays out the mechanism plainly: research is not an inducement, and can be accepted, if it’s either paid for by the investment firm itself out of its own resources, without being passed to clients as a separate charge, or paid for via an RPA that is funded and operated according to prescribed rules, including a research budget set and reviewed by the firm, not the broker.

Firms running RPAs face ongoing administrative overhead: budgeting research spend in advance, reconciling actual usage against that budget, and being ready to justify the allocation to a supervisor on request. That overhead is precisely why many mid-sized asset managers moved toward absorbing research costs directly onto the P&L rather than maintaining RPA infrastructure, a trend the market has watched closely since the original rules took hold.

Issuer-Sponsored Research: New EU Disclosure Standards Buy-Side Teams Should Know

Issuer-sponsored research, content commissioned and paid for by the company being covered, carries its own labeling requirement under MiFID II. Firms distributing this material can only call it “issuer-sponsored research” if it meets defined conditions, and buy-side consumers should treat the label as a signal to check the funding source before weighting the opinion.

Paragraphs 3b through 3e of Article 24 of MiFID II lay down rules specifically for this category. ESMA’s Final Report on the Draft Regulatory Technical Standards for the Establishment of an EU Code of Conduct for Issuer-Sponsored Research, published in October 2025, formalizes a code of conduct that issuers and research providers must follow to use the label at all.

For a buy-side analyst, this matters more than it might first appear. Issuer-sponsored research often fills coverage gaps for small and mid-cap names that sell-side desks find uneconomical to cover independently. That coverage has real value, but a report paid for by the subject company carries a different incentive structure than independent sell-side research. The label exists precisely so a portfolio manager can apply appropriate skepticism without needing to trace the commercial relationship manually.

The European Commission has continued refining technical standards tied to this framework as recently as May 2026, reference C(2026)3226, a reminder that issuer-sponsored research disclosure is not settled law. Buy-side research consumers should expect further calibration rather than treating the October 2025 RTS as a final word.

UK vs. EU: Where FCA and ESMA/AMF Rules Converge and Diverge

The UK and EU share MiFID II’s core architecture but have diverged in emphasis and implementation detail since Brexit. Buy-side firms operating across both jurisdictions need to track FCA guidance and EU/ESMA rulemaking separately rather than assuming continued alignment, particularly on research payment flexibility.

The FCA’s original UK implementation, Policy Statement PS17/14, published in July 2017, set out UK-specific rules on research payment accounts, budgeting, and client disclosure. McDermott Will & Schulte’s practitioner commentary on the final FCA rules at the time noted that the UK regime largely mirrored the EU approach at launch, giving firms a single operational playbook across both markets in the early MiFID II years.

That alignment has loosened since. The EU has continued evolving its rules through the Listing Act amendments and the more recent issuer-sponsored research RTS, while the FCA has pursued its own post-Brexit recalibration of research payment flexibility for UK-regulated firms. Meanwhile, the AMF in France frames its guidance on research funding rules explicitly around investor protection, stating the rules exist “to protect investors and limit the risks of conflicts of interest,” a framing that keeps the French regulator’s guidance tightly coupled to ESMA’s conduct-of-business objectives rather than treating research funding as a standalone commercial question.

The practical takeaway for a firm with UK and EU-regulated entities: build compliance workflows that assume divergence will widen, not narrow. A single research payment policy that satisfied both regimes in 2018 is increasingly unlikely to satisfy both in 2026.

Conflicts of Interest and Client Best-Interest Obligations in Practice

MiFID II’s research funding rules exist to manage conflicts of interest, specifically the risk that a firm’s research consumption choices are driven by inducements rather than client best interest. Buy-side compliance and portfolio management teams should treat research sourcing decisions as client-facing obligations, not back-office administration.

Hogan Lovells’ MiFID II summary on investor protection and conflicts of interest frames the research provisions as one piece of a broader conduct-of-business regime built around the same underlying principle: firms must act honestly, fairly, and professionally in accordance with client best interests, and research payment structures are one of the more concrete, auditable expressions of that principle.

Norton Rose Fulbright’s MiFID II/MiFIR series adds an important nuance many buy-side teams overlook: “recommendations” under the framework are a broader category than “investment research.” That means disclosure obligations can extend to content that wouldn’t formally qualify as research but still functions as a recommendation, a distinction that matters when a buy-side analyst receives informal commentary, model updates, or strategy notes that don’t carry a formal research label but carry investment opinions all the same.

ESMA’s Securities and Markets Stakeholder Group reinforced in its February 2025 advice that Article 24(9a) and Article 13 conditions remain a focal point of ongoing rulemaking, not a settled compliance checkbox. For a buy-side compliance officer, that means periodic re-validation of research funding arrangements against current guidance, not a one-time sign-off filed away after initial MiFID II implementation.

From Research to Action: Why Consuming Research Is Only Half the Workflow

Sourcing and paying for research correctly solves a regulatory problem, not an operational one. The real bottleneck for many buy-side teams is converting a research insight, an earnings note, a sell-side upgrade, an issuer-sponsored report, into an actual conversation with the management team or IR contact behind the numbers.

Bloomberg Professional Services’ Research & Insights hub reflects how much of the buy-side’s daily workflow is now built around consuming dense, fast-moving research output across multiple formats and providers. That density is the point: a portfolio manager covering forty names might touch a dozen research notes a day. But a research note is a static artifact. It tells you what an analyst thinks happened or will happen. It doesn’t get you fifteen minutes with the CFO to ask a follow-up question before the next print.

That gap, between reading research and acting on it, is where a lot of buy-side time actually goes. Coordinating a call with an IR team means chasing availability across time zones, tracking who on the desk already has a relationship with that contact, confirming the meeting actually happened, and logging notes somewhere the rest of the team can find them before the next research cycle starts. None of that work shows up in a compliance file. All of it shows up in a portfolio manager’s calendar as friction.

Sell-side corporate access desks solved a version of this problem years ago by building dedicated infrastructure for scheduling management meetings, coordinating roadshows, and tracking investor attendance at conferences. Buy-side teams are increasingly adopting the same category of infrastructure, not because they’re running corporate access programs themselves, but because the scheduling and documentation problem is structurally identical: high volume, high time-sensitivity, multiple stakeholders, and a need for a reliable record of who met whom and when.

Building an Efficient Buy-Side Research-to-Meeting Pipeline

An efficient buy-side pipeline connects research consumption to scheduled engagement without manual re-entry, calendar back-and-forth, or lost context between the analyst who read the note and the PM who wants the meeting. The goal is fewer emails per booked meeting and a clean, searchable record once the meeting happens.

This is the operational layer WeConvene is built for. Buy-side teams increasingly rely on the same meeting-management infrastructure sell-side corporate access desks use to convert research and coverage into scheduled engagement, whether that’s a one-on-one call with an IR contact, a slot at a broker-hosted conference, or participation in a management roadshow. The platform doesn’t touch what research says or what a portfolio manager decides to do with it; it handles the scheduling, coordination, and record-keeping that turns interest into a confirmed meeting.

For a buy-side operations team, the practical gains show up in three places. First, time saved coordinating: fewer back-and-forth emails to lock a meeting slot across firms, time zones, and calendars. Second, reduced scheduling friction across roadshow season, when a single analyst might be trying to book meetings with a dozen management teams in a compressed window. Third, better documentation: a centralized record of which meetings happened, with whom, and when, useful for both internal tracking and for demonstrating engagement patterns if a compliance review ever asks.

If your team is still tracking roadshow requests across email threads and spreadsheets, the scheduling layer is usually where the fastest gains show up, before touching anything related to research funding or compliance.

None of this changes how research gets funded, labeled, or classified under MiFID II. Those obligations sit entirely with the firm’s compliance function and the funding mechanisms covered earlier in this guide. What changes is how quickly a research-driven question turns into a scheduled, documented conversation, which is the part of the workflow that actually determines whether research gets acted on or just accumulated.

Key Takeaways for Buy-Side Research and Corporate Access Programs

Buy-side research today operates inside a tightly regulated funding framework, and the operational side of acting on that research is where firms increasingly look to purpose-built scheduling infrastructure. Both halves matter, but they are governed by different rules and solved by different tools.

The regulatory picture keeps moving. From MiFID II’s original 2018 implementation, through the RPA framework, through subsequent Listing Act amendments, to the October 2025 issuer-sponsored research RTS and the European Commission’s continued technical standards work into 2026, buy-side compliance teams should assume this is a live area requiring periodic review, not a rulebook that was finalized once and forgotten.

Separately, the operational bottleneck of converting research into meetings, calls, and roadshows is a workflow problem, not a compliance one, and it responds to better tooling rather than more policy. Firms that treat corporate access infrastructure as a buy-side tool, not just a sell-side or IR capability, tend to close the gap between “we read the note” and “we spoke to the CFO” faster.