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SNI classifier — Class 2 or Class 3

Nine conditions decide whether an investment firm is small and non-interconnected. Fail any one and the full IFR regime applies. Enter your figures and this returns an indicative classification, which conditions failed, and — the part most firms miss — when the change takes effect.

IFR Art. 12 · 9 conditions · group basis handled · transition timing shown · nothing stored

The other regime

MIFIDPRU 1.2 is a permission test on a two-year revenue average, not the nine conditions of IFR Article 12. UK SNI test →

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Enter zero where a metric does not apply to you — a firm without permission to hold client money has CMH of zero. Leave a field blank and it is treated as zero.

Size conditions

Article 12(1)(a), (b), (h), (i) — measured on a combined group basis
Assets under management (AUM) Art. 12(1)(a) · measured under Art. 17 Discretionary portfolio management plus non-discretionary assets under ongoing advice. Threshold: below €1.2 billion
Client orders handled (COH), daily Art. 12(1)(b) · measured under Art. 20 Each limb is tested against its own ceiling. Enter zero for a category you do not handle. Thresholds: cash below €100 million/day · derivatives below €1 billion/day
On- and off-balance-sheet total Art. 12(1)(h) Threshold: below €100 million
Total annual gross revenue from investment services and activities Art. 12(1)(i) Measured across the group, but intra-group double counting may be excluded. Threshold: below €30 million

Zero conditions

Article 12(1)(c) to (g) — measured individually, must each be zero
Assets safeguarded and administered (ASA) Art. 12(1)(c) · measured under Art. 19 Must be zero
Client money held (CMH) Art. 12(1)(d) · measured under Art. 18 Must be zero
Daily trading flow (DTF) Art. 12(1)(e) · measured under Art. 33 Must be zero
Net position risk (NPR) or clearing margin given (CMG) Art. 12(1)(f) · measured under Art. 22 and 23 Must be zero
Trading counterparty default (TCD) Art. 12(1)(g) · measured under Art. 26 Must be zero
What this means: an indicative classification based only on what you entered. Each metric has its own measurement rules — AUM, CMH, ASA, COH and DTF are rolling averages over defined windows, not point-in-time figures — so a figure taken off today’s balance sheet may not be the figure the condition tests. This is not advice, and it is not a notification to your competent authority.

Classification is a monitoring obligation, not an annual check. Pillar 1 Capital tracks every K-factor metric continuously and tells you when a threshold is approaching — with free capital monitoring to start.

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Timing

Not all breaches take effect the same way

This is where firms most often get caught out. Two of the nine conditions are tested one way and five another, and the difference is months of preparation time.

Immediate

The zero conditions

Exceed ASA, CMH, DTF, NPR or CMG, or TCD and the firm ceases to be small and non-interconnected straight away. There is no grace period on these five.

Three months

The size conditions

Exceed AUM, COH, the balance-sheet total or gross revenue and the firm ceases to be SNI three months after the threshold was first exceeded — not on the day it was crossed.

Six months

Coming back

A firm that has become Class 2 requalifies as small and non-interconnected only after meeting every condition continuously for six months with no breach.

Rules reviewed 21 August 2026 · IFR (EU) 2019/2033 Art. 12, consolidated text of 9 January 2024

Scope

What this classifier does

It applies the nine conditions to the figures you give it. It cannot tell you whether those figures were measured correctly — and that is where most classification errors actually originate.

It doesApply all nine conditions

  • Tests each of the nine Article 12(1) conditions and names the ones that fail.
  • Distinguishes the four size conditions from the five zero conditions.
  • Tells you whether the change takes effect immediately or after three months.
  • Flags that the size conditions are measured across the whole group where you are part of one.
  • Shows the applicable threshold beside every figure, with its Article reference.
  • Warns when a figure is close enough to a threshold that ordinary growth would cross it.

It does notMeasure the metrics for you

  • Calculate AUM, COH, ASA, CMH or DTF under their measurement Articles — each is a rolling average over a defined window with months excluded.
  • Decide whether assets under ongoing non-discretionary advice belong in your AUM.
  • Aggregate group figures or strip out intra-group double counting.
  • Account for competent authority determinations where historical data is missing.
  • Notify anyone. You must tell your competent authority as soon as you become aware you no longer satisfy the conditions.
  • Produce anything you can file. It is a test, not a return.

Already know you are Class 2?

Then your own funds requirement is the highest of the permanent minimum requirement, the fixed overheads requirement and the sum of your K-factors. Start with the fixed overheads requirement — it is the one most often misstated.

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Nothing you type here leaves your browser

The classification runs entirely in your own browser. No figure you enter is sent to REGREP, written to a log, saved to a database, or passed to any analytics tool.

Reload the page and everything is gone. Continuous monitoring against these thresholds happens inside your account, under our data processing agreement.

Questions

About SNI classification

What is the difference between Class 2 and Class 3?

Class 3 is the informal name for a firm that meets all nine conditions in Article 12(1) and is therefore small and non-interconnected. Class 2 is every other investment firm within scope of the IFR, and it faces the full regime: the K-factor requirement, the complete reporting set, and the wider governance, remuneration and disclosure obligations.

Do I measure the conditions on my own figures or the group’s?

Both, depending on the condition. AUM, COH, the on- and off-balance-sheet total and total annual gross revenue apply on a combined basis for all investment firms in the group, though intra-group double counting may be excluded from the revenue figure. The five zero conditions apply to each firm individually.

When exactly do I stop being SNI?

If you exceed AUM, COH, the balance-sheet total or gross revenue, three months after the threshold was first exceeded. If any of the zero conditions is breached, immediately. Coming back the other way takes six continuous months of meeting every condition with no breach.

My figures are just under a threshold. Does that matter?

Yes, because these are monitoring obligations rather than annual tests, and several of the metrics are rolling averages that move gradually. A firm sitting just below a threshold should know how much headroom it has and how fast it is closing, since crossing starts a clock it cannot pause.

Can I use zero for a metric I have no permission for?

Yes. A firm without permission to hold client money has CMH of zero, and a firm that does not deal on own account has DTF and NPR of zero. That is the ordinary position for advisory and portfolio management firms, and it is why most of them are SNI.

Does this work for a UK firm under MIFIDPRU?

No. The UK regime uses the same structure but sterling thresholds, and there are permission-based conditions alongside the quantitative ones. A separate MIFIDPRU classifier is planned. REGREP covers UK IFPR reporting inside the platform.

Do you store the figures I enter?

No. Everything is tested in your browser and discarded when you close or reload the page. Nothing is logged, stored or sent to analytics.

Knowing your class is the easy part.

Staying on the right side of nine thresholds that move every month is the work. Create a free account and monitor them continuously.

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