EU sets research payment account and annual research-quality assessment rules for investment firms, applying from 6 June 2026
Investment firms operating research payment accounts must meet restructured RPA, disclosure and annual research-quality rules from 6 June 2026
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Change
On 20 February 2026 the European Commission adopted Delegated Directive 2026/374 (published 2 June 2026) amending MiFID II Delegated Directive 2017/593, restructuring the conditions for separate research payment accounts, adding client-disclosure obligations on research budgets and costs, and requiring all investment firms to base their annual research-quality assessment on robust quality criteria; Member States must transpose by 5 June 2026 and apply the provisions from 6 June 2026.
Why it matters
Investment firms operating a separate research payment account must fund it through a specific client research charge, set and assess a research budget, and remain responsible for the account. They must disclose to clients the budgeted research amount and estimated charge before providing services and total third-party research costs annually, and must provide provider lists, amounts and budget-versus-spend detail on request. Research charges must not exceed the budget or be linked to transaction volume, surplus must be refunded or offset, and the budget must not fund internal research and must carry a clear audit trail under senior-management oversight. Irrespective of payment method, firms must base their annual research assessment on robust quality criteria and take remedial action on deficiencies. Member States transpose by 5 June 2026 and apply from 6 June 2026.
Implications
- — Compliance teams at investment firms operating a separate research payment account must restructure the account to meet the revised Article 13 conditions — specific client research charge, documented budget, no internal-research funding, and an audit trail referencing the quality criteria — by the 6 June 2026 application date or the RPA falls outside the permitted basis.
- — Client-reporting and operations teams at RPA-operating firms must implement pre-service disclosure of the budgeted research amount and estimated per-client charge, plus annual disclosure of total third-party research costs — these client communications become a transposed legal requirement from 6 June 2026.
- — Investment research oversight functions at all portfolio-management firms, regardless of joint or separate payment, must operate a documented annual research-quality assessment against robust criteria and act on deficiencies — the assessment obligation no longer depends on using an RPA.
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