How To Prepare For MiFID II Compliant Call Recording

*Updated 18 February 2025*

Much has been written about MiFID II, but recent research among Compliance Officers and IT Directors highlights that many UK financial services firms still struggle with full compliance. With MiFID II now firmly in place, businesses must ensure their call recording solutions meet the necessary regulatory requirements. What’s the holdup, and how can you ensure your compliance strategy remains robust? 

 

The Challenge of MiFID II Compliance 

Despite years of preparation, many compliance and IT decision-makers within financial services firms feel uncertain about the finer details of compliance. A lack of planning and inadequate technological infrastructure still leaves some firms vulnerable to non-compliance risks. 

If enterprise firms face challenges, medium-sized wealth firms with fewer resources may find compliance even more difficult, particularly those now included under MiFID II regulations for the first time. 

 

Compliance for Midsize Firms 

While some large financial services firms have established budgets and policies to address MiFID II, mid-sized firms (200–2,000 employees) may still be behind in implementation. Many remain stuck in gap analysis and policy development instead of executing the necessary technological upgrades. 

A key concern is that only a small percentage of firms are actively engaging with partners and suppliers regarding their compliance strategies. This is a missed opportunity. Partnering with experts can help address gaps and implement the right technology solutions. 

One major obligation under MiFID II is extensive trade call recording. Your business communications provider should be a trusted partner in evaluating and upgrading your call recording systems to meet compliance requirements. 

 

Understanding the Risks of Non-Compliance 

Non-compliance with MiFID II can result in severe penalties. Regulatory infractions under MiFID I led to significant fines, and enforcement under MiFID II is expected to be even stricter. While specific penalty amounts remain uncertain, firms must take a proactive approach to compliance. 

Fortunately, compliant call recording is achievable with the right strategic solutions partner. Many organisations are already working on upgrading their call recording strategies to align with MiFID II requirements. 

We partner with Uniphore (formerly Red Box Recorders), specialists in compliance communications recording, to ensure your voice recording solution meets both compliance and business needs. 

 

Key Technology Considerations 

If you already have a call recording solution in place, it’s time to assess whether it meets the stringent requirements of MiFID II: 

1. Comprehensive Recording Coverage - Ensure all relevant communications are recorded across channels and devices, including digital and mobile interactions. Verify that your corporate mobile contracts include compliant recording solutions or explore alternatives if needed. 

1. Data Retention for Five to Seven Years - Compliance requires storing recordings for at least five years, sometimes up to seven. Cloud-based storage solutions that scale with your needs can provide the necessary flexibility and capacity. 

1. Accurate Event Reconstruction Regulators – May request reconstructed client conversations. Efficient search, analytics, and reporting tools are essential to quickly retrieve and present the necessary data. 

1. Resilience and Failover Protection - Your call recording system must be reliable, with built-in monitoring to detect and flag anomalies such as missing or faulty records. Automated failover mechanisms ensure uninterrupted compliance in case of technical issues. 

1. Ongoing Management and Compliance Testing - Regular testing and monitoring of your recording process are crucial. A managed service option can help maintain system performance, particularly if internal resources are stretched. 

 

Training and Continuous Improvement 

Training Risk & Compliance Managers and IT staff on call recording systems will help build internal knowledge and streamline compliance management. Employees must be familiar with record storage, retrieval, and event reconstruction processes. 

 

Next Steps 

If you need support with your MiFID II call recording compliance, contact us at 01483 242526, or reach out to the our team for expert guidance. While compliance remains an ongoing challenge, the right technology and partnerships can ensure your business remains compliant and future-ready.