Finansinspektionen Amends Three Securities Regulations to Align With MiFID II Delegated Directive

Key Takeaways

• On September 15, 2026, Finansinspektionen (FI) adopted amendments to three regulations in the securities area to reflect the amended MiFID II delegated directive adopted in connection with the EU Listing Act.
• The changes take effect October 1, 2026, which leaves a short implementation window for investment firms, fund managers, and AIFMs operating in Sweden.

Deep Dive

On September 15, 2026, Finansinspektionen (FI) adopted amendments to three regulations in the securities area to reflect the amended MiFID II delegated directive adopted in connection with the EU Listing Act. The changes take effect October 1, 2026, which leaves a short implementation window for investment firms, fund managers, and AIFMs operating in Sweden.

Teams should therefore review the full text of the three amending regulations and any accompanying FI memorandum. They should also map those changes against the amended EU delegated directive and the Listing Act package. Likely areas of impact, to be confirmed against the text, include provisions in the securities transactions rules that overlap with MiFID II organizational and conduct requirements. Because the fund regulations reference these provisions, they may be affected too.

The key date is October 1, 2026, which is about two weeks after publication. Firms should confirm immediately whether the amendments require changes to policies, procedures, systems, or client documentation. Firms that already implemented the underlying EU delegated directive requirements may need only limited adjustments. Those that relied on the prior Swedish wording may have more work, and the short runway raises the risk of non-compliance on day one.

Recommended actions:
- Obtain the final texts of FFFS 2026:28, 2026:29, and 2026:30.
- Run a gap analysis against current policies, procedures, and controls.
- Assign owners and set a remediation plan with milestones before October 1, 2026.
- Update compliance monitoring plans, training materials, and regulatory inventories.
- Coordinate across the securities, UCITS, and AIFM business lines to ensure consistent implementation.
- Document any assumptions or interpretive positions, and consider engaging FI if the text is unclear.

The overall risk is moderate. The changes appear to be alignment and consequential amendments rather than a new regime, but the compressed timeline and the cross-regulation scope create implementation and supervisory risk. Firms that fail to update documentation or processes may face supervisory findings.

Source: Finansinspektionen