Suitability — responsibility matrix (MiFID II Art. 25(2))

Status (2026-05-19): PARKED — Phase A pre-license. Stratify Signals does not run MiFID-II suitability today. The matrix below describes the post-license state that re-enters when the FMA VVG license is granted (Phase C). Until then the engine in lib/suitability/ does not exist and partners do not delegate suitability to Stratify.

Closed-beta / v2.1 baseline. Legal review owns final wording; engineering owns implementation traceability.

Roles

Topic	Stratify	Partner (neobroker)
Suitability assessment	Performs scoring & pass/fail using Stratify engine on answers submitted via B2B-API	Collects answers in partner UX; must not apply own pass/fail for copy-trading eligibility
Disclosure to retail user	Provides outcome categories / mandated copy via API errors & B2C surfaces where applicable	Presents Stratify-approved disclosures only; no reinterpretation
Record retention	Stores full answer snapshot + engine output + version hash (audit)	Stores correlation ids / partner user refs per DPA
KYC / AML	Sumsub (or contracted vendor) on Stratify-led B2C flow	Partner KYC for their relationship; Stratify KYC for Stratify-regulated activity per flow design
Loss-bearing capacity	Engine enforces quantitative caps	Supplies accurate numeric inputs; does not coerce answers

Evidence bundle (per suitability decision)

Minimum fields persisted by Stratify (see lib/suitability/ + audit payloads):

Questionnaire version / schema id
Normalised answers (machine-readable)
Per-dimension scores, total score, hard-fail codes (if any)
Timestamp and actor (partner_api_key id or system)

Change control

Any change to weights, thresholds, or hard-fail rules requires:

Compliance sign-off
Version bump in engine + migration note
Regression tests (lib/suitability/engine.test.ts + fixtures)