Do Investors Benefit From MiFID II Unbundling?

52 Pages Posted: 26 Jul 2021 Last revised: 21 Jun 2023

See all articles by Emelie Fröberg

Emelie Fröberg

Stockholm School of Economics

Michael Halling

University of Luxembourg

Date Written: June 21, 2023


One prominent aspect of the MiFID II regulation that became effective in Europe in 2018 is the unbundling of research and execution costs. We exploit the early adoption of an unbundling rule in Sweden already in 2016 to provide evidence on the implications for fund investors. Using a difference-in-difference framework and mostly hand-collected data on bundled and unbundled commissions, we find no economically meaningful effect of unbundling on commissions. When we split the sample into more active and less active funds, using the Active Share measure, we find that fund costs of more active funds increased in relative terms. Finally, we fail to identify improved fund performance or any information gains for investors’ fund selection process from the increased transparency of observing execution and research costs separately. Overall, we are skeptical that investors benefited from the unbundling of commissions.

Keywords: Financial Intermediation, Mutual Funds, MiFID II, Unbundling

JEL Classification: G11, G23

Suggested Citation

Fröberg, Emelie and Halling, Michael, Do Investors Benefit From MiFID II Unbundling? (June 21, 2023). Available at SSRN: or

Emelie Fröberg (Contact Author)

Stockholm School of Economics ( email )

PO Box 6501
Stockholm, 11383

HOME PAGE: http://

Michael Halling

University of Luxembourg ( email )

L-1511 Luxembourg

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