On April 24, the European Commission commenced infringement proceedings against 24 EU member states for failing to implement the Markets in Financial Instruments Directive (MiFID) into their national law. At present, only the UK, Ireland and Romania have met their obligations under the Directive under which they were required to implement the new MiFID requirements before January 31 to give EU firms sufficient time to prepare for the November 1 date on which MiFID requirements come into force.

It is rare for infringement proceedings to run their full course. Although their commencement triggers a formal process that could potentially reach the European Court of Justice, the Commission’s goal is to force the non-complying member states to step up the pace of their implementation of this significant Directive.