On 18 November 2015, ESMA published a note (dated 2 October 2015) on the possibility of a delay in the implementation of MiFID II.

The note explains that it is unlikely that the Level 2 provisions will be published before March 2016. This will leave less than nine months to develop the systems needed for MiFID II implementation, which ESMA acknowledges is insufficient for the most complex systems. ESMA estimates that the delay could be by up to one year.

On 27 November 2015, the European Parliament’s MiFID II negotiating team informed the European Commission that it is ready to accept a one-year delay of the entry into force of MiFID II subject to certain conditions.