Q&A · ESMA

Records / audit trail / digital workflows / use of user credentials / Record-keeping and audit trail for “under supervision” in digital/segregated advisory workflows

Rejected

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AI-generated Summary

Sought clarification of record-keeping for staff advising 'under supervision' under ESMA's knowledge and competence guidelines (ESMA/2015/1886), including evidence of sign-off and the use of a qualified person's credentials in digital workflows. ESMA rejected the question, so there is no answer.

Details

Reference	ESMA_QA_2791
Issuer	ESMA
Published	26 Feb 2026
Submitted	26 Feb 2026
ESMA topics	Suitability
Former reference	follow-up to ESMA email ref. 26-0343 + Submitted Question (ESMA_QA_2790)

Provisions it relates to

Article 25 MiFID II · Assessment of suitability and appropriateness and reporting to clients
MiFID II
Inferred · 75%
MiFID II (whole act)
Explicit reference

Documents it refers to

Delegated actIn forceExplicit reference
Commission Delegated Regulation (EU) 2017/565 of 25 April 2016 supplementing Directive 2014/65/EU of the European Parliament and of the Council as regards organisational requirements and operating conditions for investment firms and defined terms for the purposes of that Directive
European Commission · 31 Mar 2017 · EUR-Lex
AI summaryThe main MiFID II Delegated Regulation: defines key terms (such as investment advice, systematic internaliser, algorithmic and high-frequency trading, and direct electronic access) and sets detailed organisational requirements and operating conditions for investment firms, including compliance, conflicts of interest, remuneration, client information, suitability and appropriateness, best execution, client order handling, reporting to clients, record keeping and transaction-level obligations.