PRIIPs requirements made clearer

The European Commission has taken its first steps towards ending uncertainty for firms affected by the PRIIPs regulation, an incoming rule that requires product providers, advisers and intermediaries to provide additional information to potential investors in the form of a 3-page Key Information Document (KID). For a recap of the regulation - and to find out whether it affects you - check out the FCA's handy summary, here.

To date, the PRIIPs rollout has been beset by delays and uncertainty. It was originally due to come into force at the beginning of 2017, but was pushed back following political disagreement over the finer details. Today's news is a big step forward: a batch of Regulatory Technical Standards (RTS) have been published, which for the first time allows firms to examine the rules close-up.

Despite weighing in at a dense 20 pages, the document will come as a relief to firms already bracing for MiFID II (which comes into force simultaneously). Now that many of the basic details are confirmed, those affected can start laying the groundwork for PRIIPs in good time.

So, what have we learned?

At a high level, we now know that the 3 page KIDs will be comprised of 8 key sections, as follows:

1. General information
2. What is this product?
3. What are the risks and what could I get in return?
4. What happens if [product provider] is unable to pay out?
5. What are the costs?
6. How long should I hold it and can I take my money out early?
7. How can I complain?
8. Other relevant information

Fuller details of what goes into each section can be found in the core publication - here - and the Commission has also produced a template which firms are expected to follow (here).

It's worth noting that despite this new information, populating the template will still be a reasonably onerous task. As well as stipulating basic layout and content, there are detailed rules on how different pieces of information are to be presented. In particular, the 'riskiness' of products must be calculated on the basis of a standardised 7-point scale, details of which are in the template appendix.

While it's not yet clear whether this is the Commission's final word on the matter, the new publication allows firms to get preparations well underway.

As for us, we'll be digesting the detailed rules over the coming weeks and helping firms meet the standard in time for January. If you'd like help assembling your KIDs, or simply some advice or a quick review, just get in touch.