[ESMA35-43-349 MiFIDII Investor protection Q&As Ch2 question 5]

Yes. Firms providing investment advice are required to always provide the client with a suitability report, irrespective of the specific recommendation given, including the advice not to buy, hold or sell a financial instrument. 

In this regard, Recital 87 of the MiFID II Delegated Regulation specifically clarifies that “investment firms should undertake a suitability assessment not only in relation to [when] recommendations to buy a financial instrument are made but for all decisions whether to trade including whether or not to buy, hold or sell an investment”.