Product Governance Self-Assessment Questionnaire

A free annual distributor self-assessment template for EU-regulated investment firms, covering MiFID II product governance arrangements from governance and target market through to Board reporting.

What this is

This Product Governance Self-Assessment Questionnaire is a structured tool for EU investment firms to evaluate their distributor-side MiFID II product governance arrangements. It is designed for use during the annual compliance review cycle and walks compliance officers, senior managers and internal auditors through the substantive elements of product governance oversight.

The questionnaire is grounded in MiFID II Articles 16(3) and 24(2),Commission Delegated Directive (EU) 2017/593 (Articles 9 and 10),Commission Delegated Directive (EU) 2021/1269 sustainability amendments, and the ESMA Guidelines on MiFID II product governance requirements (ESMA35-43-3448, applicable from 3 October 2023).

What is inside

The questionnaire is organised into eight sections plus six annexes.

Eight sections:

• Firm details and scope
• Governance and oversight
• Product universe and selection
• Target market and distribution strategy
• Information flow and exceptions
• Product review and client outcomes
• Compliance monitoring and Board reporting
• Overall conclusion and action plan

Six annexes:

• Annex 1: Product categories in scope
• Annex 2: Products selected for detailed review
• Annex 3: Product-level review table (target market, distribution, sales monitoring, conclusions)
• Annex 4: Information flow and exceptions register
• Annex 5: Product review and client outcome data
• Annex 6: Evidence register

Who this is for

The questionnaire is designed for compliance officers, senior managers, internal auditors and persons responsible for product governance oversight at EU-regulated investment firms that distribute financial instruments. It covers retail, professional and eligible counterparty distribution.

It focuses on distributor-side obligations. Firms that also manufacture financial instruments should separately assess their manufacturer obligations under Article 9 of the Delegated Directive.

Important

This questionnaire is a general-purpose template based on publicly available EU regulatory requirements. It is not legal or compliance advice and is not tailored to any specific firm, business model, product range or jurisdiction. Users should adapt the content to their own circumstances and seek qualified legal or compliance advice where appropriate.

Related content

For a practical walkthrough of the distributor framework and the typical gaps supervisors examine, read Product Governance Self-Assessment for Distributors: What Supervisors Actually Examine on the CPDs.Academy blog.

For deeper substantive coverage, including the manufacturer-side framework, the target market assessment process step by step, and the practical implementation of distributor obligations, our seminar Practical Implementation of Product Governance delivers CPD-eligible training for compliance and regulatory professionals.