Even in 2025, the major banks and financial intermediaries continue to exhibit significant shortcomings in the preparation and communication of annual cost and charges statements related to investment services. This is confirmed by an analysis conducted by Plus24 of Il Sole 24 Ore on a sample of 22 industry operators, which highlights how — seven years after the entry into force of MiFID II — transparency for end clients remains a goal still far from being achieved.

Nomenclature and Format: Partial Improvements

Only 77% of intermediaries include the wording “costs and charges” in the title of the document, as required by Consob and ESMA guidelines. A figure that has grown from 64% in 2024, yet remains unsatisfactory given the importance of correct document identification by the client.

The presence of irrelevant content within the statements remains high: 52% of the documents analysed contain redundant or marginally relevant sections, which risk diluting the information that is crucial for the investor. The average length is 8.6 pages, with some reaching 16–18 pages, particularly where the statement is combined with other documents (e.g. portfolio management reports). Although Consob permits this practice, it recommends that cost information be placed on the first pages with adequate graphical emphasis.

Client Communication: Still a Critical Stage

One of the most deficient aspects concerns the manner in which the statement is communicated. In only 17.4% of cases did clients receive a notification (by email, SMS, or pop-up) confirming that the document had been published in the restricted area of their online banking portal. In many other cases, the document is uploaded with no notification whatsoever, making it difficult to locate. Some institutions explicitly state that they do not provide notifications.

This practice undermines the effectiveness of the regulatory obligation and erodes investors’ financial awareness. A sound practice — not yet widely adopted — would be to request an acknowledgement of receipt, as already occurs with other contractual documents.

Cost Items: What to Examine Carefully

In order to fulfil the informational function required by MiFID II regulation, the statement must:

  • disclose all costs incurred by the client (in both absolute value and percentage terms);

  • distinguish between costs relating to services (e.g. advisory fees), relating to instruments (funds, insurance products, securities) and third-party payments (retrocession commissions);

  • include the impact on returns (the difference between the gross and net portfolio return);

  • report tax charges, included in the total in 9 out of 10 documents but not always shown separately;

  • clearly inform the client of the possibility of requesting a detailed breakdown of cost items.

  • cost items.

Also under scrutiny are retrocession commissions — that is, the incentives paid by product manufacturers to the intermediary for the distribution of their financial instruments. This is a significant item which, for collective investment funds in Italy, can represent up to 70% of the overall cost. It is a legitimate practice, but one that must be made transparent: in “independent” advisory services, moreover, such retrocessions are not permitted and the client pays the adviser directly.

What the Investor Can (and Should) Do

Clients, often unaware of these matters, can and should:

  • actively search for the document in the restricted online area;
  • seek support from their adviser to interpret the data correctly;
  • request, when not provided, a detailed breakdown of the costs incurred, including the share allocated to each party involved (the bank, the product manufacturer, and the adviser).

The regulatory objective — to increase transparency, trust, and awareness in investments — remains only partially fulfilled. Intermediaries have the opportunity to transform a compliance obligation into a relationship-building tool and a means of demonstrating the value of the service they provide. Transparency on costs is not a risk to be avoided, but a competitive differentiator and a client’s right.