EU Regulatory Analysis and Level 2 Engagement Support


H/Advisors Cicero was approached by Plus500 to support in preparing a comprehensive report on European and domestic approaches by financial services regulators (ESMA, BaFin, CNMV, CySEC, etc.). The report was to look at offering Contracts for Difference (CfDs) to retail investors in the context of ESMA’s review of the MiFID II Product Governance Guidelines review.

We were then tasked with preparing an engagement plan on behalf of Plus500 to prevent a de facto ban of CfD trading for retail investors through the revised guidelines.

Strategy & Execution

We conducted research across EU, Member State and IOSCO recommendations, reports and rules applicable to the CfD industry. We also completed a comprehensive assessment of responses submitted to Calls for Evidence by ESMA and the Commission in the retail investment space. This aimed to understand what information/advocacy is currently before those bodies for their consideration in the context of the Guidelines review.

We undertook comprehensive and prioritised stakeholder mapping. This identified key targets within ESMA’s two relevant stakeholder groups (Securities and Markets Stakeholder Group and the Investor Protection and Intermediaries Standing Committee Consultative Working Group) as well as the ESMA team in charge of reviewing the revised MiFID II guidelines.​ We then developed and implemented a six-month engagement plan to ensure Plus500’s views were well-reflected in the final version of the guidelines. ​

“The compliance and regulatory services Cicero and specifically, Mr. Alexandros Nikolaidis, provided have been excellent and always given with great care. Cicero is a team of hardworking, knowledgeable people who have provided us with an extremely strong level of service and great response time.”

Ofir Chudin, Chief Executive Officer, Plus500CY


Plus500’s executive team now has a complete view of the CfD regulatory ecosystem across the European Union and can make informed strategy decisions as to priority markets.

ESMA took into account Plus500’s positioning in the preparation of the final MiFID II product Governance Guidelines, retaining the existing regime requiring comprehensive target market assessments before CfDs are offered to retail investors. Crucially they are not going as far as a de facto ban on the service.