PRIIPs: Key Information Document Guidelines

At its heart, the Packaged Retail and Insurance-based Investment Products Regulation (“PRIIPs Regulation”) requires retail investors to be provided with a PRIIPS Key Information Document (“KID”) as per Articles 5 and 13 of the PRIIPs Regulation. For further details of PRIIPs, including links to both the Regulation and the Regulatory Technical Standards (which concerns the required contents of a KID and prescribed template), please see Regulatory Roundup 87.

Guidelines (“Communication from the Commission”) on the application of the KID under PRIIPs have now been published.

It’s fairly modest in length – four pages in total – but clarifies various areas including, but not limited to:

• Distribution of a PRIIP to a retail investor without a KID is a breach of EU Regulation 1286/2014 (see below).
• Even if a PRIIP is sold exclusively by persons other than the PRIIP manufacturer, the latter is required to prepare and publish a KID on its website.
• A KID must be a maximum of three sides of A4 when printed.
• Where a PRIIP is only made available outside the European Union, no KID is required.
• No adaptation to the KID, including titles and sequence of sections, is permitted.