MiFID II RTS 6
A modern operating model for RTS 6 assurance.
Annual RTS 6 assessment involves more than completing a questionnaire. Firms must establish scope, assess requirements, gather evidence, demonstrate controls, identify deficiencies and maintain appropriate governance around review and approval. Cerylis brings that process into one connected workspace.
A connected operating model
From scope to accountable approval.
01 — Scope
Determine which RTS 6 requirements apply to relevant algorithms, systems and activities.
02 — Requirements
Manage the assessment at granular regulatory-requirement level rather than through a single narrative document.
03 — Controls
Connect the firm’s control framework directly to the regulatory requirements it supports.
04 — Evidence
Associate policies, procedures, testing records and other supporting evidence with the relevant assessment.
05 — Assessment
Record a clear compliance conclusion and supporting rationale.
06 — Challenge
Allow second-line reviewers to comment, request further evidence and challenge conclusions.
07 — Approval
Maintain clear ownership, review status and sign-off history.
Regulatory context
“Key policy documentation was not linked or referenced in some self-assessments.”
Financial Conduct Authority — Multi-firm review of algorithmic trading controls, August 2025
Evidence should be part of the assessment — not stored somewhere else.
Cerylis links regulatory conclusions directly to the controls and evidence supporting them, helping reviewers understand not only the conclusion reached, but the basis for it.
Regulatory context
ESMA expects article-by-article assessment
“Investment firms shall conduct and document the required self-assessment on an article-by-article basis, covering all relevant articles of RTS 6.”
Cerylis structures RTS 6 assurance at requirement level — connecting each conclusion to its rationale, controls, evidence and review history.
Requirement → Conclusion → Rationale → Controls → Evidence → Review
See the assurance process, not just the dashboard.
Regulatory Assurance Workspace
RTS 6 • 2026 Review Cycle
ASSURANCE
Requirements
Controls
Evidence
Assessments
Approvals
RTS 6 / Article 15 / Pre-trade controls
Order entry controls and kill functionality
Mapped to accountable owners, controls and review evidence for the current assessment period.
Evidence ready
Linked evidence
3 items
Pre-trade control operating test
Control owner: Electronic Trading • Reviewed 18 Aug
Kill switch exception report
Control owner: Market Risk • Challenged 21 Aug