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IncreasingMedium2026-07-22

BaFin bans payment for order flow for neobrokers

MarketsGuidanceGeneral RegulatoryCapital MarketsGermanyConf: High
Regulatory Event

BaFin issued a supervisory statement prohibiting credit institutions and investment firms from accepting PFOF payments for forwarding client orders.

Analysis

BaFin's supervisory statement operationalises the EU MiFIR PFOF ban, specifying dos and don'ts for neobrokers. Firms relying on PFOF revenue must restructure commercial models, execution arrangements, and best-execution frameworks, with implications for pricing and client disclosures.

Relevance

PFOF prohibition materially reshapes retail broker economics, best-execution governance, and inducement compliance in Germany.

Required Action

Action Required

Terminate PFOF arrangements, revise execution policies, and update disclosures and revenue models to align with MiFIR-derived rules.

Justification

Direct supervisory clarification on PFOF affects revenue models and conduct frameworks of all German-facing brokers.

Control Commentary

Assess PFOF exposure across order-routing arrangements; update best-execution and inducements policies; document remediation plan and evidence to BaFin timelines.

Source

Credit institutions and investment firms are no longer permitted to accept payments or non-monetary benefits from third parties in return for forwarding client orders. BaFin makes this clear in a new supervisory statement.

RH-2026-07-23-012