MiFID II Suitability Report Template (Art. 25(6), Del. Reg 2017/565 Art. 54)

Retail suitability statement: profile used, recommendation, reasons, sustainability, risks, costs, switching, review, inducements, delivery, checklist

ISO 与合规完整MiFID II Art. 25(2), 25(6), 29a; Delegated Reg (EU) 2017/565 Art. 50, 52, 54 (as amended by 2021/1253); ESMA35-43-3172mifid suitability report math更新于 2026年10月24日

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使用方法: Use it when a MiFID investment firm gives a retail client investment advice or starts a portfolio management mandate. Fill the client profile summary and the recommendation table first, then the reasons criterion by criterion, costs and switching analysis. The main pitfall is boilerplate reasons that would fit any client, or delivering the report after the transaction without the distance-communication consent and delay option.

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Suitability Report: [Client name], [Report reference]

Written statement on suitability that an investment firm gives a retail client when it provides investment advice, and the updated statement it includes when it manages a portfolio. It records the client profile used, the recommendation, why it is suitable (objectives, time horizon, knowledge and experience, attitude to risk, capacity for loss and sustainability preferences), its disadvantages, the costs and their cumulative effect, any switching analysis, the need for periodic review, inducements and conflicts, and the delivery record. Based on MiFID II (Directive 2014/65/EU) Article 25(2) and 25(6), as amended by Directive (EU) 2021/338, Commission Delegated Regulation (EU) 2017/565 Articles 50, 52, 54 and 55, as amended by Delegated Regulation (EU) 2021/1253 (sustainability preferences, applying from 2022-08-02), and the ESMA Guidelines on certain aspects of the MiFID II suitability requirements (ESMA35-43-3172). EU Retail Investment Strategy amendments are pending and not yet in force as of 2026-10. Replace every [bracketed] value and every row marked Example. This is a document format, not financial, investment, tax or legal advice. Obtain the directive, regulation and guidelines for the normative text.

Document control

Field	Value
Document ID	[SR-YYYY-NNN]
Version	[1.0]
Status	[Draft / Checked / Approved / Delivered / Superseded]
Owner	[@adviser]
Approvers/reviewers	[@supervisor], [@compliance-officer]
Last updated	YYYY-MM-DD
Classification	[Confidential: client personal data]
Firm	[Legal name], authorised by [competent authority], [licence number]
Client(s)	[Names], client reference [CL-NNN]
Client category	[Retail / Professional (opted in to suitability report)]
Service	[Investment advice (independent / non-independent) / Portfolio management / Advice on entering a portfolio management mandate]
Client risk profile used	[CRP-ID], dated YYYY-MM-DD
Report type	[Initial / Periodic (changes only) / Ad hoc after trigger event]
Language and medium	[Language], [PDF by secure portal / paper]

Example: SR-2026-041, Mara and Theo Lind, retail clients of Kestrel Bay Capital Europe (fictional MiFID investment firm), initial suitability statement for a discretionary portfolio management mandate of EUR 200,000 that replaces an existing account at another provider. Risk profile CRP-2026-118 dated 2026-09-30.

Approvals

Role	Name	Decision	Date
Adviser	[Name]	[Prepared]	YYYY-MM-DD
Supervisor or second-line reviewer	[Name]	[Approved / Returned with comments]	YYYY-MM-DD
Compliance (sampled or high-risk files)	[Name]	[Reviewed / Not in sample]	YYYY-MM-DD

Revision history

Version	Date	Author	Change
0.1	YYYY-MM-DD	[@adviser]	First draft after the recommendation meeting
1.0	YYYY-MM-DD	[@adviser]	Approved and delivered to the client
[x.y]	YYYY-MM-DD	[@author]	[Change]

Report details and service type
Your needs and objectives
The client profile we used
Our recommendation
Why the recommendation is suitable for you
Sustainability preferences
Disadvantages and risks
Costs and charges
Switching analysis
Periodic review
Inducements conflicts and independence
Jurisdiction notes
Declaration delivery and records
Internal file note and suitability checklist
Glossary and references
Standard and licence note

1. Report details and service type

This report explains the recommendation we made to you on [date of meeting] and why we consider it suitable for you. Please read it carefully before you agree to the transaction or sign the mandate. If anything is unclear or wrong, tell us before you proceed.

Item	Detail
Meeting dates and channel	[YYYY-MM-DD, in person / video / telephone (recorded)]
Adviser	[Name], [qualification held under national competence rules]
Service provided	[Investment advice / Portfolio management]
Basis of advice	[Independent / Non-independent], because [reason]
Range considered	[Types of instruments and number of providers analysed]
Relationship with providers	[None / Group products included: names]
Periodic suitability assessment offered	[Yes, annually / No]
Scope limits agreed with you	[Only the investment account; pensions and property excluded]

Example: Kestrel Bay Capital Europe provides portfolio management on a non-independent basis. The models use funds and ETFs from 14 unrelated providers and two funds managed by the US affiliate Kestrel Bay Capital; those two funds are identified in section 11. The advice in this report covers the decision to enter the mandate and to move the existing investment account. Pensions, the family home and the employer shares held outside the account are outside the scope, but we took them into account in assessing your financial situation.

2. Your needs and objectives

Restate each objective in the words agreed with the client, with its amount, date and priority. The summary should be specific enough that the client recognises their own situation and a reviewer can test the recommendation against it.

Goal ID	What you told us	Amount and date	Priority
OBJ-001 (Example)	Build a pot to supplement your pensions from 2042	About EUR 590,000 nominal by 2042	Essential
OBJ-002 (Example)	Fund university costs for your two children	About EUR 66,000 nominal, drawn 2032 to 2037	Important
OBJ-003 (Example)	Help your children with a first home deposit	No fixed amount, after 2040	Aspirational
[OBJ-NNN]	[Goal]	[Amount, date]	[Priority]

You also told us that you do not need income from the account before 2032, that your emergency reserve of 7.3 months of essential spending is held separately, and that you prefer a simple portfolio of funds over individual shares (Example).

3. The client profile we used

Our recommendation is based on the information you gave us in the client risk profile [CRP-ID] dated YYYY-MM-DD. Please tell us if anything has changed since then: we rely on that information unless we know or should know that it is out of date, inaccurate or incomplete (Delegated Regulation 2017/565 Article 55(3)).

Element	Outcome	Evidence
Financial situation	[Summary]	CRP section 2
Investment term	[Years per goal]	CRP section 3
Knowledge and experience	[Per product type]	CRP section 4
Attitude to risk (willingness)	[Band]	CRP section 5.1
Capacity for loss	[Amount and rating]	CRP section 5.2
Combined risk rating	[Band per sleeve]	CRP section 5.3
Sustainability preferences	[Choices on the three elements]	CRP section 6
Liquidity needs and constraints	[Summary]	CRP section 7
Support needs	[Adjustments agreed]	CRP section 8

Example: net worth about EUR 673,000 including the home; capacity for loss EUR 50,000 on the mandate (rated Medium); both holders have experience of funds and ETFs and no experience of structured products or derivatives; attitude to risk Growth for Mara (score 34) and Balanced for Theo (score 29), with the firm's joint-account rule applying the lower band; combined rating Balanced (3) for the retirement sleeve and Cautious (2) for the education sleeve; at least 20% sustainable investments and consideration of greenhouse gas emissions and controversial weapons. Theo asked for written summaries two days before each review.

4. Our recommendation

Describe the recommendation in enough detail that the client can see what will be bought, sold, kept or transferred, in what amount and when. If the firm decided not to recommend because nothing on its range is suitable, record that decision and the reasons here instead (Delegated Regulation 2017/565 Article 54(10)).

Rec ID	Action	Instrument, model or service	Amount	Timing
REC-001 (Example)	Open	Discretionary mandate, retirement sleeve, Model B (Balanced), sustainable variant	EUR 160,000	On signature
REC-002 (Example)	Open	Discretionary mandate, education sleeve, Model C (Cautious), sustainable variant	EUR 40,000	On signature
REC-003 (Example)	Transfer in kind	Four ETFs from the existing account that are in the Model B universe	EUR 92,000 of the EUR 200,000	Within 15 business days
REC-004 (Example)	Sell and reinvest	Three active funds that cannot be transferred or are not in the universe	EUR 108,000 of the EUR 200,000	After transfer completes
REC-005 (Example)	Monthly contribution	Direct debit split 1,200 retirement and 300 education	EUR 1,500 a month	From the next month
REC-006 (Example)	No action (outside scope, noted)	Employer shares of EUR 40,000 held by Theo outside the mandate	Not applicable	Review a selling plan at the next trading window

The amounts in REC-003 and REC-004 add up to the EUR 200,000 mandate (92,000 + 108,000). The model allocations are:

Model	Growth assets	Defensive assets	Main building blocks
Model B Balanced (Example)	55%	45%	Global equity index funds with sustainability screens, euro government and corporate bond funds, cash
Model C Cautious (Example)	25%	75%	Same building blocks with more short-dated bonds

5. Why the recommendation is suitable for you

Explain the fit criterion by criterion. Each reason should refer to a fact in the profile and to a feature of the recommended service or product. Where a criterion is only partly met, say so and explain why the recommendation is still in your interest.

Criterion	How the recommendation meets it
Investment objectives and term	[Link each REC to each OBJ]
Attitude to risk	[Model band versus profile band]
Capacity for loss	[Illustrative stress loss versus capacity]
Knowledge and experience	[Products used versus products known]
Financial situation and liquidity	[Reserve, withdrawals, debts]
Sustainability preferences	[See section 6]
Cost and complexity versus alternatives	[Equivalent options considered]

Example reasons:

Objectives and term. The retirement sleeve has a 16-year horizon before drawdown, long enough to hold a Balanced model through periods of falling markets. The education sleeve starts to pay out in 2032, so it uses the Cautious model and will move further into short-dated bonds from 2030, as agreed in the investment policy statement.
Attitude to risk. Mara's answers pointed to Growth and Theo's to Balanced. Our joint-account rule applies the lower band, so the retirement sleeve uses Balanced. You both confirmed this in the meeting.
Capacity for loss. The illustrative stress loss of the recommended portfolio is 20% x EUR 160,000 + 12% x EUR 40,000 = EUR 32,000 + EUR 4,800 = EUR 36,800, which is below the EUR 50,000 you could absorb without changing an essential goal. A Growth model for the whole mandate (28% x EUR 200,000 = EUR 56,000) would not pass this test.
Knowledge and experience. The models hold only funds and ETFs, which you have both bought before. No structured products or derivatives are used, in line with your profile.
Financial situation. Your reserve stays outside the mandate, no withdrawal is planned before 2032, and the monthly contribution of EUR 1,500 comes from a monthly surplus of EUR 2,300, leaving EUR 800 as a buffer (Example figures from CRP section 2.1). The mandate is 29.7% of your net worth (200,000 / 673,000), and your employer pensions of EUR 185,000 secure a base retirement income.
Cost and complexity. We compared the mandate with two equivalent options: keeping your existing account and rebalancing it yourself, and a single multi-asset fund. Section 9 shows the cost comparison. The mandate costs more than the single fund but separates the two goals and applies your sustainability preferences, which the single fund does not.

Use the formula below when you illustrate the capacity test for a multi-sleeve recommendation:

L_{\text{stress}} = \sum_{i=1}^{n} s_i \times V_i \le C_{\text{loss}}

where $s_i$ is the illustrative stress loss of sleeve $i$ , $V_i$ its value and $C_{\text{loss}}$ the capacity for loss from the profile.

6. Sustainability preferences

Compare each preference with the data the product manufacturer reports (for funds, the pre-contractual and periodic disclosures under Regulation (EU) 2019/2088 and the European ESG Template data where used). Ask about sustainability preferences only after the other objectives, and do not let them override risk or capacity.

Element	Your choice	Recommended portfolio	Met?
(a) Minimum taxonomy-aligned share	[%]	[% reported]	[Yes / No / Adapted]
(b) Minimum sustainable investments share	[%]	[% reported]	[Yes / No / Adapted]
(c) Principal adverse impacts considered	[PAI indicators]	[Products and indicators]	[Yes / No / Adapted]
Exclusions outside the three elements	[Detail]	[Screens applied]	[Yes / No]

Example: you chose no minimum for (a), at least 20% for (b), and consideration of greenhouse gas emissions and exposure to controversial weapons for (c). The sustainable variants of Model B and Model C report 26% and 22% sustainable investments respectively, weighted by the product data at 2026-09-30. Across the mandate this gives 0.8 x 26% + 0.2 x 22% = 25.2%, above your minimum of 20%, and every fund in both models considers the two PAI indicators you chose. Your preferences are met without adaptation.

7. Disadvantages and risks

List the risks that matter for this client and this recommendation, and the disadvantages compared with the alternatives. Use the manufacturer's documents (key information documents, prospectuses) for product risks, and add the risks created by the advice itself.

Risk or disadvantage	What it means for you	How it is managed
Market risk	The value of the portfolio will rise and fall; you may get back less than you invest	Diversified models, horizon matched to goals
Sequence risk for the education sleeve	A fall shortly before 2032 would reduce the money available for university costs	Cautious model, glide path from 2030
Currency risk	Part of the equity funds invest outside the euro area	Hedged bond funds; equity currency exposure accepted
Out-of-market risk during the switch	Prices may move between the sale of old funds and the purchase of new ones	Transfer in kind where possible; sale and purchase on the same dealing day
Tax on switching	Selling funds may realise taxable gains	[Tax adviser] to confirm before REC-004
Discretion	We make day-to-day decisions without asking you first	Mandate limits, quarterly reports, loss threshold notifications
Higher cost than a single fund	Section 9 shows the difference	Separate sleeves and sustainability filter justify it
[Risk]	[Effect]	[Mitigation]

Where a portfolio management mandate applies, tell the client about the loss notification: a portfolio manager informs the client when the overall value, as valued at the start of the reporting period, falls by 10% and at each further multiple of 10%, by the end of that business day (Delegated Regulation 2017/565 Article 62(1)).

8. Costs and charges

State the conventions: currency, amount invested, period, and whether figures are estimates. Ex-ante figures use actual costs incurred as a proxy where available (Article 50(8)).

Cost item	% per year	EUR in year 1 on EUR 200,000	Type
Portfolio management fee (Example)	0.80%	1,600	Service, ongoing
Custody and platform (Example)	0.05%	100	Service, ongoing
Transaction costs of the service (Example)	0.04%	80	Transaction
Fund ongoing charges, weighted (Example)	0.16%	320	Product, ongoing
Transaction costs inside funds (Example)	0.05%	100	Transaction
One-off switching dealing costs (Example)	0.20% (once)	400	Service, one-off
Exit fee charged by the current provider (Example)	0.075% (once)	150	Service, one-off (charged by the ceding provider, shown so that all one-off costs of the switch are aggregated)
Third-party payments received by the firm	0.00%	0	Inducements (none, see section 11)
Total year 1	1.375%	2,750
Total in later years	1.10%	2,200

Illustration of the cumulative effect of costs on return. The return assumption is illustrative, not a forecast: 4.0% a year before costs. After ongoing costs of 1.10% the return is taken as 2.9% a year, and the one-off costs of EUR 550 (dealing 400 plus exit fee 150) are deducted at the start. Costs are deducted from the annual return rate, which is an approximation; the exact form is $(1+r)(1-c)$ and gives a slightly lower net value.

V_{\text{gross}}(t) = P(1+r)^t, \qquad V_{\text{net}}(t) = (P - c_0)(1 + r - c)^t

Year	Value without costs (EUR)	Value after costs (EUR)	Cumulative effect (EUR)
1 (Example)	208,000.00	205,234.05	2,765.95
3 (Example)	224,972.80	217,310.23	7,662.57
5 (Example)	243,330.58	230,096.98	13,233.60

With $P = 200{,}000$ , $c_0 = 550$ , $r = 4.0\%$ and $c = 1.10\%$ . The cumulative effect includes the return that the costs would have earned. Ex-post costs are reported to you every year in the annual cost statement (Article 50(9)).

9. Switching analysis

Compare the existing arrangement with the recommendation on cost, risk, fit to objectives and features. Include one-off costs of the switch. State the conclusion in one sentence the client can understand.

Item	Existing account (Example)	Recommended mandate (Example)
Ongoing costs per year	1.45% (platform 0.30%, funds 1.05%, transactions 0.10%)	1.10%
Ongoing costs in EUR per year on EUR 200,000	2,900	2,200
Risk level	About 85% equity, above your Balanced profile	Balanced and Cautious sleeves matched to goals
Sustainability preferences	Not applied	Met (section 6)
Separate goal tracking	No	Yes
One-off costs of switching	Not applicable	EUR 550 (dealing EUR 400 plus exit fee EUR 150)
Tax on realised gains	Not applicable	[Amount to be confirmed by tax adviser]

Payback on costs alone: annual saving EUR 700 (2,900 minus 2,200); one-off cost EUR 550; payback 550 / 700 = 0.79 years, about 9.4 months, before any tax on realised gains.

Example conclusion: in our view the benefits of switching are greater than the costs, because the switch lowers ongoing costs, brings the risk level in line with your profile and applies your sustainability preferences. The conclusion depends on the tax position, which your tax adviser will confirm before we sell the three funds in REC-004.

10. Periodic review

State whether the client needs to seek a periodic review of their arrangements, and what the firm will do. Firms providing a periodic suitability assessment review the suitability of their recommendations at least annually and more often where the risk profile or the instruments require it.

Item	Detail
Review needed	[Yes / No], because [reason]
Frequency	[Annual / Semi-annual]
Information reassessed	[Full profile every [n] years; changes every year]
Trigger events for an earlier review	[Job change, inheritance, health, goal date approaching, 10% loss notification]
How updates are communicated	[Updated suitability statement in periodic report]
Record	Client Portfolio Review (`finance/client-portfolio-review`)

Example: the mandate includes an annual review in October. Every second year we refresh the full profile; in other years we ask about changes. The education sleeve is reviewed each year from 2029 to set the glide path. Your quarterly report will include an updated statement of how the portfolio still meets your objectives and preferences.

11. Inducements conflicts and independence

Item	Disclosure
Third-party payments received	[None / Amount and treatment]
Minor non-monetary benefits	[Training events, research under the minor benefits rules]
Group or related products in the recommendation	[Names and weights]
Adviser remuneration	[Fixed salary; no product-related variable pay]
Other conflicts	[Reference to register entries]

Example: Kestrel Bay Capital Europe receives no payments from fund providers for this mandate. Model B includes one fund managed by the US affiliate Kestrel Bay Capital (6% of the sleeve); the selection was reviewed against two unrelated alternatives on cost and tracking, and the conflict is recorded as COI-014 in the conflicts register. Your adviser's pay does not depend on the products selected.

12. Jurisdiction notes

As of 2026-10. Check the current law and the competent authority's rules in each jurisdiction.

Jurisdiction	Rule set (names and numbers)	Notes for this report
EU	MiFID II Art. 24, 25, 29a; Delegated Reg (EU) 2017/565 Art. 50, 52, 54, 55, 62; ESMA35-43-3172	National transposition and competent authority rules apply
EU (pending)	Retail Investment Strategy package (provisional agreement December 2025)	Not in force; expected to add value-for-money and inducement test changes; suitability broadly retained. Track the Official Journal
UK	FCA Handbook COBS 9A (suitability for MiFID business), COBS 9 (other business), PRIN 2A Consumer Duty	FCA consultations in 2026 propose merging advice rules; reference only, obtain the Handbook text
US	SEC Regulation Best Interest (17 CFR 240.15l-1) for broker-dealers; Advisers Act fiduciary duty (Release IA-5248, 2019) for advisers; FINRA Rule 2111	No MiFID-style suitability report; document the basis of recommendations and the Form CRS delivery
[Other]	[Rule]	[Note]

13. Declaration delivery and records

Adviser declaration. I confirm that this recommendation is based on the client profile referred to in section 3, that the reasons in section 5 reflect the information the client gave, and that I have explained the risks, costs and alternatives.

Item	Detail
Delivered by	[Secure portal / email / post / in person]
Delivery date and time	YYYY-MM-DD hh:mm
Before the transaction	[Yes / No: distance-communication exception used]
If exception used: client consent recorded	[Reference]
If exception used: option to delay offered	[Reference]
Client acknowledgement	[Signed / Portal confirmation / Not required]
Professional client opt-in to report	[Yes, dated YYYY-MM-DD / Not applicable]
Records location	[Client file path], retained for [period under national law]

Client acknowledgement (optional). We have read this report. The information about us in section 3 is correct and complete as of the date below.

Client	Signature	Date
[Name]		YYYY-MM-DD
[Name]		YYYY-MM-DD

14. Internal file note and suitability checklist

Check ID	Requirement (reference)	Report section	Done
SR-CHK-001	Profile complete and current (Reg 2017/565 Art. 54(2) to (8))	3	[ ]
SR-CHK-002	Basis of advice and range explained (Art. 52)	1	[ ]
SR-CHK-003	Outline of the advice given (Art. 54(12))	4	[ ]
SR-CHK-004	Fit to objectives, term, knowledge, risk, capacity for loss (Art. 54(12))	5	[ ]
SR-CHK-005	Sustainability preferences met or adaptation recorded (Art. 54(10), (12))	6	[ ]
SR-CHK-006	Equivalent, less costly or complex options considered (Art. 54(9))	5, 9	[ ]
SR-CHK-007	Disadvantages and risks of the recommendation (ESMA35-43-3172)	7	[ ]
SR-CHK-008	Ex-ante costs and cumulative effect illustration (Art. 50(2), (10))	8	[ ]
SR-CHK-009	Switching cost-benefit analysis (MiFID II Art. 25(2); Art. 54(11))	9	[ ]
SR-CHK-010	Periodic review need and arrangements (Art. 52(5), 54(12), (13))	10	[ ]
SR-CHK-011	Inducements and conflicts disclosed (MiFID II Art. 24(8), 24(9), 23)	11	[ ]
SR-CHK-012	Delivery before the transaction or valid exception (MiFID II Art. 25(6))	13	[ ]
SR-CHK-013	Product is within the target market or deviation justified (`compliance/mifid-target-market-assessment`)	4, 14	[ ]

Example file note: SR-2026-041 checked on 2026-10-14 by the supervisor. All checks met. Target market: all funds in Model B and Model C list retail clients with basic knowledge and a medium-term or long-term horizon as their positive target market; no deviation.

15. Glossary and references

Term	Meaning in this report
Suitability	Whether a recommendation fits your objectives, finances, knowledge and attitude to risk
Capacity for loss	The fall in value you could absorb without changing an essential goal or your standard of living
Attitude to risk	How much fluctuation in value you are willing to accept
Durable medium	A format you can store and reproduce unchanged, such as a PDF
Portfolio management	A service in which we make investment decisions for you within agreed limits
Switching	Selling an investment to buy another, or changing the terms of an existing one
Sustainable investment	An investment that meets the definition in Article 2(17) of Regulation (EU) 2019/2088
Principal adverse impacts	The most significant negative effects of investment decisions on sustainability factors
Target market	The group of clients for whom a product is designed

References (obtain the official texts):

Directive 2014/65/EU (MiFID II), Articles 16, 23, 24, 25, 29a, as amended by Directive (EU) 2021/338 (applied from 2022-02-28) and Directive (EU) 2024/790.
Commission Delegated Regulation (EU) 2017/565, Articles 2(7), 50, 52, 53, 54, 55, 62 and 72, as amended by Delegated Regulation (EU) 2021/1253 (applies from 2022-08-02).
ESMA Guidelines on certain aspects of the MiFID II suitability requirements, ESMA35-43-3172 (applied from 2023-10-03).
Regulation (EU) 2019/2088 (SFDR) and Regulation (EU) 2020/852 (Taxonomy), for sustainability preference data.
SEC Release IA-5248 (2019) and Regulation Best Interest, for US comparison only. FINRA Rule 2111 and the FCA Handbook are cited by number only.

Standard and licence note

Based on Directive 2014/65/EU (MiFID II), Directive (EU) 2021/338, Commission Delegated Regulation (EU) 2017/565 and Delegated Regulation (EU) 2021/1253 as published on EUR-Lex (reuse authorised with acknowledgement under Commission Decision 2011/833/EU), and on the structure of the ESMA Guidelines ESMA35-43-3172 (source: ESMA, esma.europa.eu; this template is not endorsed by ESMA, and the guidelines are available free of charge on the ESMA website). US references are to public SEC materials. FCA Handbook modules and FINRA rules are cited by reference only. All text is original; no legislative or guideline text is reproduced, and article numbers are given so that the reader can check the requirement. The client names, Kestrel Bay Capital Europe and all figures are fictional. Check the current consolidated texts, national transposition and any adopted Retail Investment Strategy changes before use. This is a document format, not financial, investment, tax or legal advice. Template licence: MIT.