Best Execution Policy Template (MiFID II Art. 27, Delegated Reg 2026/825, SEC)

Order execution policy: factor ranking by class, venue and broker list, routing, allocation, instructions, OTC price checks, PFOF ban, TCA thresholds, review

ISO та комплаєнсПовнийMiFID II Art. 27 (as amended by 2024/790); MiFIR Art. 39a; Delegated Reg (EU) 2017/565 Art. 64-70; Delegated Reg (EU) 2026/825; SEC IA-5248best execution policy mathОновлено 24 жовт. 2026 р.

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Як використовувати: Use it when an investment firm executes client orders, places them with brokers in portfolio management or transmits them. Fill the scope by service, the factor ranking per class and the venue list first, then the monitoring thresholds. The main pitfall is still producing RTS 28 reports while running TCA without thresholds or follow-up, and missing that Delegated Regulation 2026/825 applies from 2028-02-12.

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Best Execution Policy: [Firm name]

Order execution policy and its monitoring framework for an investment firm that executes client orders, places them with brokers in portfolio management, or receives and transmits them. It sets the execution factors and their relative importance by asset class, the venues and brokers used and how they are selected, order handling and allocation, treatment of specific instructions, costs and the ban on payment for order flow, monitoring and transaction cost analysis, annual review, client information and records. Based on MiFID II (Directive 2014/65/EU) Articles 24, 27 and 28 as amended by Directive (EU) 2024/790 (transposition by 2025-09-29), MiFIR (Regulation (EU) No 600/2014) Article 39a as inserted by Regulation (EU) 2024/791, Commission Delegated Regulation (EU) 2017/565 Articles 64 to 70, and Commission Delegated Regulation (EU) 2026/825 on order execution policies (applies from 2028-02-12). US rows reflect the SEC interpretation of the adviser's duty of care (Release IA-5248, 2019). Replace every [bracketed] value and every row marked Example. This is a document format, not legal or investment advice. Obtain the law and the rules for the normative text.

Document control

Field	Value
Document ID	[POL-BEX-001]
Version	[1.0]
Status	[Draft / Approved / Superseded]
Owner	[@head-of-trading]
Approvers/reviewers	[@management-body], [@best-execution-committee], [@compliance], [@risk]
Last updated	YYYY-MM-DD
Classification	[Internal; client summary public]
Entities covered	[Legal names, licences, competent authorities]
Services covered	[Execution of orders / Portfolio management / Reception and transmission / Dealing on own account]
Client categories	[Retail / Professional / Eligible counterparties (out of scope under MiFID II Art. 30)]
Effective date	YYYY-MM-DD
Next annual review	YYYY-MM-DD

Example: POL-BEX-001 version 3.0 for Kestrel Bay Capital Europe (fictional MiFID investment firm: portfolio management and reception and transmission of orders for retail and professional clients) and, in the US rows, its affiliate Kestrel Bay Capital (fictional SEC-registered investment adviser). Kestrel Bay Capital Europe does not deal on own account; it executes euro bond orders itself by request for quote on multilateral trading facilities and places all other orders with approved brokers.

Approvals

Body or role	Name	Decision	Date
Management body	[Chair]	[Approved]	YYYY-MM-DD
Best execution committee	[Chair]	[Recommended]	YYYY-MM-DD
Compliance	[Name]	[Reviewed]	YYYY-MM-DD

Revision history

Version	Date	Author	Change
2.0	YYYY-MM-DD	[@head-of-trading]	RTS 28 top-five report removed after Directive (EU) 2024/790 transposition
3.0	YYYY-MM-DD	[@head-of-trading]	Restructured for Delegated Regulation (EU) 2026/825; payment for order flow ban confirmed after national exemptions ended on 2026-06-30
[x.y]	YYYY-MM-DD	[@author]	[Change]

Purpose scope and legal basis
Governance and responsibilities
Execution factors and their relative importance
Classes of instruments and execution approach
Execution venues and brokers
Order routing criteria
Order handling aggregation and allocation
Specific client instructions
Price fairness for OTC instruments
Costs commissions and payment for order flow
Monitoring and transaction cost analysis
Annual review and material change
Client information and consent
Records
Jurisdiction notes
Glossary and references
Standard and licence note

1. Purpose scope and legal basis

The firm takes all sufficient steps to obtain, on a consistent basis, the best possible result for its clients when it executes their orders, or when it places or transmits orders with other entities for execution. Best possible result does not mean the best price on every single order; it means a process that is designed to achieve the best result across orders and is shown to work through monitoring.

Service or flow	Obligation (reference)	Section
Execution of client orders	MiFID II Art. 27(1), (4), (5), (7); Del. Reg. 2017/565 Art. 64, 66	3 to 13
Portfolio management placing orders with brokers	Del. Reg. 2017/565 Art. 65(1), (4) to (7)	5, 11, 12
Reception and transmission of orders	Del. Reg. 2017/565 Art. 65(2), (4) to (7)	5, 11, 12
Client order handling	MiFID II Art. 28; Del. Reg. 2017/565 Art. 67 to 70	7
Payment for order flow	MiFIR Art. 39a	10
Execution of client orders, from 2028-02-12	Del. Reg. (EU) 2026/825 Art. 2 to 9 (apply as good practice to Art. 65 placement and transmission flows)	4 to 6, 11, 12
US adviser trades	Advisers Act fiduciary duty of care (Release IA-5248)	15

Out of scope: transactions with eligible counterparties (MiFID II Article 30), except where the firm has agreed otherwise, and subscriptions or redemptions of fund units dealt at net asset value with the fund's transfer agent, where the only factor the firm controls is the timing of the order and the share class chosen.

Example: all three flows apply to Kestrel Bay Capital Europe: execution (euro bonds by request for quote), portfolio management (equities, ETFs and listed derivatives through brokers) and reception and transmission (advisory clients' orders passed to brokers).

2. Governance and responsibilities

Role	Responsibility
Management body	Approves the policy and receives the annual effectiveness report
Best execution committee	Approves venue and broker list changes, reviews monitoring results, decides remediation
Head of trading	Owns the policy, factor tables and routing rules; first-line monitoring
Traders	Apply the policy, record the rationale for non-standard execution
Compliance	Independent testing, exception review, client complaint review
Risk	Counterparty and operational risk assessment of venues and brokers
Operations	Settlement quality data, failed trade reporting

Committee Example: chair is the chief operating officer, members are the head of trading, the head of portfolio management, compliance and risk; meets quarterly and after any trigger in section 12; quorum three members including compliance; minutes kept for five years.

3. Execution factors and their relative importance

The relative importance of the factors depends on the characteristics of the client (retail or professional), of the order (size, urgency, securities financing transaction), of the instrument and of the venues available (Delegated Regulation 2017/565 Article 64(1)). For retail clients, total consideration (price plus all costs directly related to execution, including venue, clearing and settlement fees) takes precedence; other factors count only to the extent that they improve total consideration.

Class	Client	1st	2nd	3rd	4th	Notes (Example)
Shares, liquid	Retail	Total consideration	Likelihood of execution	Speed	Size	Total consideration decides
Shares, liquid	Professional	Price	Market impact (size)	Costs	Likelihood	Algorithms used for orders above 10% of average daily volume
Shares, small cap	Both	Likelihood of execution	Price	Size	Costs	Liquidity drives the outcome
ETFs	Both	Price (spread to fair value)	Likelihood	Costs	Size	Request for quote to market makers for large orders
Bonds	Both	Price	Likelihood of execution	Size	Settlement	At least three quotes where available
Listed derivatives	Professional	Price	Speed	Likelihood	Costs	Exchange-traded only
FX for settlement	Both	Price (spread)	Costs	Speed	Settlement	Compared with an independent benchmark rate
Fund units at NAV	Both	Timing	Costs (share class)	Not applicable	Not applicable	No venue choice; outside the best execution scope (section 1), shown for order handling only

Record the reason whenever a trader departs from the ranking, for example by giving speed precedence ahead of an announced event.

4. Classes of instruments and execution approach

Classes in the Annex of Delegated Regulation 2026/825 (names abbreviated): shares and depositary receipts; ETFs, ETNs and ETCs; certificates and other equity-like instruments; bonds and money market instruments; structured finance products; options and futures admitted to trading on a trading venue; other derivatives; contracts for difference; emission allowances; other instruments.

Class ID	Class (Annex)	Sub-class (firm)	Execution method	Who executes
CL-01 (Example)	Shares and depositary receipts	EU large and mid cap	Broker algorithms on lit and dark venues	Approved brokers
CL-02 (Example)	Shares and depositary receipts	Small cap and blocks	Broker high-touch, block venues	Approved brokers
CL-03 (Example)	ETFs, ETNs, ETCs	All	Request for quote to at least three market makers above EUR 500,000; on exchange below	Brokers and RFQ platforms
CL-04 (Example)	Bonds and money market instruments	Euro government and corporate	Request for quote on MTFs	Firm (execution)
CL-05 (Example)	Options and futures on a trading venue	Index futures	Direct market access through clearing broker	Approved brokers
[CL-NN]	[Class]	[Sub-class]	[Method]	[Who]

5. Execution venues and brokers

5.1 Internal list

Venue or broker ID	Name and identifier (LEI or MIC)	Approved on	Approved by	Classes	Transaction types	Client types	Limitations
VEN-001 (Example)	[Broker A], LEI [code]	2025-03-12	Best execution committee	CL-01, CL-02	Cash equity, no SFT	Retail and professional	None
VEN-002 (Example)	[Broker B], LEI [code]	2025-03-12	Best execution committee	CL-01, CL-03, CL-05	Cash equity, futures	Retail and professional	Futures for professional clients only
VEN-003 (Example)	[Bond MTF 1], MIC [code]	2024-11-07	Best execution committee	CL-04	Cash bonds	Retail and professional	None
VEN-004 (Example)	[Bond MTF 2], MIC [code]	2026-02-19	Best execution committee	CL-04	Cash bonds	Professional	Retail orders only if no quote on VEN-003
[VEN-NNN]	[Name, ID]	YYYY-MM-DD	[Body]	[Classes]	[Types]	[Clients]	[Limits]

Record the measures the firm takes to confirm that each venue is authorised by its competent authority, or by the third-country authority (Delegated Regulation 2026/825 Article 2(1)(b)).

5.2 Selection and review criteria

Select venues and brokers by reference to the characteristics and needs of the clients and to the execution factors, including the order types available, typical order sizes and frequencies, execution prices compared with reference data, and the fees and costs the firm pays (execution and trading fees, membership and connectivity, clearing, settlement and custody).

Broker scorecard (Example), weights add up to 100%:

Criterion	Weight	Broker A score (1 to 5)	Weighted
Execution quality versus benchmarks	40%	4	1.60
Total cost (commission and fees)	20%	3	0.60
Settlement quality (fails, timeliness)	15%	5	0.75
Operational and counterparty risk	15%	4	0.60
Service, access to liquidity, reporting	10%	4	0.40
Total	100%		3.95

Brokers scoring below 3.00 for two consecutive quarters are placed on watch; below 2.50 they are suspended pending committee review (Example thresholds).

5.3 Single venue justification

If one venue or one broker is used for a class or for all orders, explain why that choice obtains the best possible result on a consistent basis and compare it periodically with alternatives (Delegated Regulation 2026/825 Articles 3(3) and 8(3)).

Class	Single venue or broker	Justification	Last comparison
[Class]	[Name]	[Reason, data]	YYYY-MM-DD

6. Order routing criteria

Criterion	Retail orders	Professional orders
Class of instrument	Determines the eligible venues	Determines the eligible venues
All execution-related costs including the firm's own commissions	Decisive with price (total consideration)	Considered with price
Size and nature of the order	Only where it changes total consideration	Algorithm and venue choice
Market data, including historical data	Fill rates and price improvement by venue	Fill rates, market impact, venue toxicity

Automatic order routing (Example): Broker A's smart order router is used for CL-01. The firm reviews the router's documented logic each year, receives venue-level fill data monthly and tests that routing follows total consideration for retail orders. Record the main characteristics of any router and the arrangements that keep it consistent with these criteria.

7. Order handling aggregation and allocation

Rules:

Record each order with time, client or account, instrument, side, size, order type and any instruction before it is worked.
Execute otherwise comparable client orders in the sequence received, unless the order characteristics or market conditions make this impracticable or client interests require otherwise.
Tell retail clients promptly about any material difficulty in carrying out their orders.
Aggregate client orders, or client and own-account orders, only under the conditions of Article 68 and Article 69 of the Delegated Regulation, and allocate under the pre-set allocation below.
Allocate partial fills pro rata to the pre-trade intended quantities, at the average price, unless a documented exception applies (minimum lot sizes, de minimis amounts).

Partial fill (Example): an aggregated buy order for 30,000 shares for three portfolios (15,000, 10,000 and 5,000) is 80% filled (24,000 shares at an average price of EUR 42.57). Pro rata allocation: 12,000, 8,000 and 4,000 shares, each at EUR 42.57. Check: 12,000 + 8,000 + 4,000 = 24,000.

8. Specific client instructions

Clients are warned clearly that a specific instruction may prevent the firm from following the steps in this policy for the parts of the order the instruction covers (Delegated Regulation 2017/565 Article 66(3)(f)). The firm treats only the instructed aspect as instructed and applies this policy to all other aspects of the order.

Instruction type	Treated as specific instruction for	Policy still applies to
Client names a venue	Venue	Timing, order type, price within the venue
Client sets a limit price	Price limit	Venue, routing, timing within the limit
Client asks for execution at the close	Timing	Venue choice for the closing auction
Client chooses one of several options offered by the firm	The option chosen	All other aspects

If the firm invites retail clients to choose a venue, it must not steer the choice by its pricing; where commissions differ by venue, it explains the differences (Delegated Regulation 2017/565 Article 64(3) and 66(4), (5)). If the client does not choose, the order is routed under this policy.

9. Price fairness for OTC instruments

Class	Reference data (Example)	Data provider	Fallback
Euro government bonds	Composite mid price at time of execution	[Provider]	Comparable bonds of the same issuer and maturity
Euro corporate bonds	Composite price, evaluated price	[Provider]	Spread to a comparable bond or curve
FX forwards	Spot plus forward points from an independent source	[Provider]	Internal model from interest rate differentials
[Class]	[Data]	[Provider]	[Fallback]

Bond request for quote (Example): sell EUR 2,000,000 nominal of a euro corporate bond. Quotes received: 98.62, 98.55 and 98.70. Executed at 98.70 with the best bidder; clean proceeds EUR 1,974,000 (2,000,000 x 0.9870). Improvement against the second-best quote: 0.08 points x EUR 20,000 per point = EUR 1,600. Composite mid at execution was 98.78, so the execution was 0.08 points (8.1 basis points of price) below mid, within the Example threshold of 15 basis points for investment-grade corporate bonds of this size.

The firm does not deal on own account. A firm that does must specify how it obtains the best result when dealing against the client, how it manages the conflict, how it checks price fairness against market prices or, failing that, comparable instruments or a model (Delegated Regulation 2026/825 Article 6).

10. Costs commissions and payment for order flow

Rules:

The firm does not receive any fee, commission or non-monetary benefit from a third party for executing client orders on a particular venue or for forwarding them to a third party for execution on a particular venue (MiFIR Article 39a(1)). Rebates or discounts on venue fees under a public tariff are acceptable only if they benefit the client exclusively and give the firm no monetary benefit.
Commissions are set per class and are disclosed in the client fee schedule. Where commissions differ by venue, the differences are explained to clients.
Any inducement related to execution venues is disclosed and must comply with MiFID II Article 24(9) (Delegated Regulation 2017/565 Article 66(6)). Research paid with execution commissions follows the Research and Soft Dollar Policy (compliance/research-and-soft-dollar-policy).
Portfolio management: third-party payments are not accepted or kept, other than minor non-monetary benefits disclosed to clients (MiFID II Article 24(8)).

Retail total consideration (Example): a retail client buys 200 shares at EUR 42.57; firm commission 0.10% (EUR 8.51), venue and clearing fees EUR 1.50. Total consideration EUR 8,514.00 + 8.51 + 1.50 = EUR 8,524.01. A venue showing EUR 42.56 with EUR 4.00 fees gives EUR 8,512.00 + 8.51 + 4.00 = EUR 8,524.51 (commission unchanged), so the first venue gives the better total consideration despite the worse price.

11. Monitoring and transaction cost analysis

11.1 Measures

Implementation shortfall for a fully executed buy order, in basis points of the arrival value:

IS_{\text{bp}} = \frac{Q\,(\bar{P}_{\text{exec}} - P_{\text{arrival}}) + C + F}{Q\,P_{\text{arrival}}} \times 10{,}000

where $Q$ is the quantity, $\bar{P}_{\text{exec}}$ the average execution price, $P_{\text{arrival}}$ the price when the order reached the desk, $C$ the commission and $F$ other fees. For a sell order, reverse the sign of the price term.

Example: buy 10,000 shares, arrival price EUR 42.50, average execution EUR 42.57, commission 4 basis points on EUR 425,700 (EUR 170.28), fees EUR 25.00.

Component	EUR	Basis points of EUR 425,000
Price (10,000 x 0.07)	700.00	16.47
Commission	170.28	4.01
Fees	25.00	0.59
Total implementation shortfall	895.28	21.07

The result is within the Example threshold of 25 basis points for CL-01 orders between 5% and 10% of average daily volume.

11.2 Thresholds and sample

Class	Reference data	Accepted deviation (Example)	Minimum share of volume within reference (Example)	Minimum orders in sample (Example)
CL-01	Arrival price and venue best bid and offer, consolidated tape where available	25 bp implementation shortfall	95%	200 per quarter
CL-03	Fair value from creation basket (iNAV)	10 bp from iNAV	90%	50 per quarter
CL-04	Composite mid at execution	15 bp from mid	90%	100 per quarter
[Class]	[Data]	[Deviation]	[%]	[Number]

11.3 Exceptions and follow-up

Exception ID	Date	Order and class	Breach	Root cause	Action	Closed
BEX-EXC-001 (Example)	2026-08-14	Buy small-cap shares, CL-02	62 bp shortfall versus 40 bp threshold	Liquidity fell after a profit warning; trader prioritised completion	Rationale accepted; no broker issue	2026-08-21
BEX-EXC-002 (Example)	2026-09-03	Sell bond, CL-04	Single quote only	Illiquid issue	Price checked against evaluated price; accepted	2026-09-05
[BEX-EXC-NNN]	YYYY-MM-DD	[Order]	[Breach]	[Cause]	[Action]	YYYY-MM-DD

12. Annual review and material change

The review covers at least: monitoring results and exceptions; fees and costs paid to venues and brokers; market developments, including liquidity dry-ups, and their effect on venues; new venues and their functions, fees, transparency and liquidity; venues that disappeared; and, where a single venue is used, a comparison with alternatives.

Trigger ID	Material change (Example)	Action
MC-001	A venue or broker relied on significantly is lost, merged or degraded	Out-of-cycle review, client notification
MC-002	Monitoring shows non-compliance with the policy or the Article 27(1) duty	Root cause, remediation plan, committee decision
MC-003	New consolidated tape data or new venue changes the best available result	Review venue list and routing
MC-004	Regulatory change (for example, Delegated Regulation 2026/825 application on 2028-02-12)	Policy update and approval

Annual review record (Example): review of 2026-10-08 covered 4,812 orders. CL-01: 96.4% of volume within threshold (minimum 95%); CL-04: 88.0% within threshold (minimum 90%), traced to one MTF with thin dealer participation in high-yield issues. Action: extend VEN-004 to retail high-yield orders and require two venues for every high-yield RFQ; re-test in Q1 2027.

13. Client information and consent

The client summary contains, adapted to the class and service (Delegated Regulation 2017/565 Article 66(2), (3)):

the relative importance of the factors, or the process to set it;
the venues or brokers relied on significantly, per class and for retail, professional and securities financing orders;
the factors used to select venues, including qualitative ones;
whether orders may be executed outside a trading venue, the consequences such as counterparty risk, and more detail on request;
a clear warning about specific instructions;
a summary of venue selection, execution strategies and how execution quality is monitored and verified.

Item	Method	Record
Policy summary delivered	[Durable medium / website under the Article 3(2) conditions]	[Date, version]
Prior consent to the policy	[Account opening form, tick box]	[Reference]
Express consent to execution outside a trading venue	[General agreement / per transaction]	[Reference]
Notification of material changes	[Email, portal]	[Date, version]
Venue of execution for instruments under trading obligations	[Trade confirmation field]	MiFID II Art. 27(3) as replaced
Demonstration on request	[Process, response time]	MiFID II Art. 27(8)

The public annual reports on execution venues and the top five venues (RTS 27 and RTS 28) are no longer required in the EU; do not describe them to clients as a regulatory publication. Check whether national law or Delegated Regulation 2017/565 Article 65(6) in its current consolidated form still requires any publication for portfolio managers and transmitting firms.

14. Records

Record	Content	Retention (Example)
Order record	Time stamps, instructions, routing, venue, fills	5 years, or longer if national law requires
Quotes and RFQ log	Dealers asked, quotes, time, winner	5 years
Reference price snapshots	Composite or tape prices used for checks	5 years
Trader rationale for exceptions	Free text with time stamp	5 years
Monitoring and TCA reports	Monthly, quarterly, annual	5 years
Committee minutes and venue approvals	Decisions, approvers, data used	5 years
Client consents and notifications	Policy version, dates	Life of relationship plus 5 years
Telephone and electronic communications	Order-related	As required by MiFID II Art. 16(7) and national law

15. Jurisdiction notes

Jurisdiction	Rule set (names and numbers)	Notes as of 2026-10
EU	MiFID II Art. 24, 27, 28 (as amended by Directive (EU) 2024/790); MiFIR Art. 39a; Del. Reg. 2017/565 Art. 64 to 70; Del. Reg. (EU) 2026/825	2026/825 applies from 2028-02-12; public RTS 27 and RTS 28 reporting removed; payment for order flow banned, national exemptions ended 2026-06-30
UK	FCA Handbook COBS 11.2A (MiFID business), COBS 11.2 and 11.2B; PRIN 2A Consumer Duty	FCA removed RTS 27 and RTS 28 reporting from 2021-12-01 (PS21/20). Reference only; obtain the Handbook
US, investment adviser	Advisers Act fiduciary duty: duty of care includes the duty to seek best execution (SEC Release IA-5248, 2019); Form ADV Part 2A Item 12 brokerage practices; Exchange Act Section 28(e) for research	Periodic and systematic evaluation of execution quality is expected; disclose soft dollar and directed brokerage practices
US, broker-dealer	FINRA Rule 5310 (cited by number only); SEC Regulation NMS order routing disclosures	Applies to the broker, not to the adviser
[Other]	[Rule]	[Note]

16. Glossary and references

Term	Meaning
Best possible result	The outcome the policy is designed to achieve for clients on a consistent basis, judged on the execution factors
Total consideration	Price of the instrument plus all costs directly related to execution, for retail clients
Execution venue	Regulated market, MTF, OTF, systematic internaliser, market maker or other liquidity provider, or a similar third-country entity
Request for quote (RFQ)	Asking several dealers for prices before trading
Implementation shortfall	Difference between the value at arrival price and the value achieved, including costs
iNAV	Indicative net asset value of an ETF during the trading day
Payment for order flow	A payment from a third party for sending client orders to a particular venue
Consolidated tape	A single stream of trade and quote data across venues, published by an authorised provider

References (obtain the official texts):

Directive 2014/65/EU (MiFID II), Articles 16, 24, 27, 28 and 30, as amended by Directive (EU) 2021/338 and Directive (EU) 2024/790.
Regulation (EU) No 600/2014 (MiFIR), Article 39a, inserted by Regulation (EU) 2024/791.
Commission Delegated Regulation (EU) 2017/565, Articles 64 to 70 and 72.
Commission Delegated Regulation (EU) 2026/825 of 14 April 2026 on the criteria for establishing and assessing the effectiveness of order execution policies (OJ L series, 23 July 2026), repealing Delegated Regulations (EU) 2017/575 and (EU) 2017/576.
SEC Release IA-5248, Commission Interpretation Regarding Standard of Conduct for Investment Advisers (effective 2019-07-12).
FCA PS21/20, FCA Handbook COBS 11.2A and FINRA Rule 5310, cited by reference only.

Standard and licence note

Based on Directive 2014/65/EU (MiFID II) as amended by Directive (EU) 2024/790, Regulation (EU) No 600/2014 as amended by Regulation (EU) 2024/791, and Commission Delegated Regulations (EU) 2017/565 and 2026/825, as published on EUR-Lex (reuse authorised with acknowledgement under Commission Decision 2011/833/EU), and on SEC Release IA-5248 (US public material). FCA Handbook modules and FINRA rules are cited by reference only. All text is original; no legislative text is reproduced, and article numbers are given so that the reader can check each requirement. Kestrel Bay Capital Europe, Kestrel Bay Capital, the brokers, venues and all figures are fictional. Check the current consolidated texts, national transposition and the application date of Delegated Regulation (EU) 2026/825 before use. This is a document format, not legal or investment advice. Template licence: MIT.

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