Systematic Internaliser

Regulatory requirements in the European Union (EU) and the United Kingdom (UK) conduct legislation applicable to Systematic Internalisers (SI) have changed. These changes in regulation will have an impact on the wider financial services industry. AFME, ICMA and ISDA have published guidance containing further details in this regard, which addresses reporting considerations across asset classes.

With respect to Deutsche Bank AG’s SI obligations:

• For bonds, derivatives, and other MiFID non-equity instruments: Due to these changes, effective from December 2025 in UK and April 2026 in EU, Deutsche Bank AG deregistered from its current status as an SI for bonds and derivatives, as well as other MiFID non-equity instruments. As a consequence of these regulatory changes, Deutsche Bank AG will no longer publish a commercial policy in respect of such instruments as the requirement to do so no longer applies to it.
• For MiFID II equity and equity-like instruments: In addition, due to changes in its operating models and effective from April 2026, Deutsche Bank AG also deregistered its current status as an SI with respect to equity and equity-like instruments with applicable regulators in the EU and the UK in all MiFID II equity asset classes.

In each case, trade execution, market-making and liquidity provision will remain unaffected by Deutsche Bank AG’s SI de-registration.

Last updated: April 2026