All outstanding issues on the PRIIPs Regulation must be appropriately addressed in the
RTS to provide the required legal certainty, otherwise industry will not be able to timely and
correctly implement these new rules
The European Banking Federation, Insurance Europe, the European Fund and Asset Management Association (EFAMA) and the European Structured Investment Products Association reconfirm their full support for the objectives of the PRIIPs initiative. In light of consumer protection, the PRIIP Key Information Document (KID) can be a valuable tool enabling retail investors to compare products and, hence, make informed investment decisions. However, in order to enable consumers to benefit from the KID, the Regulatory Technical Standards (RTS) would need to be clear, consistent and fit for purpose, which we strongly believe is not the case today. In contrast, as they currently stand, the RTS will not allow the KID to provide consumers with a good understanding and comparative tool of the products on the markets.
While we welcomed the intention of the European Commission and the ESAs to provide clarity on all outstanding questions on the RTS via the implementation workshop on the PRIIPs Regulation on 11 July, we strongly believe that this objective has unfortunately not been met. Most of the many essential technical issues raised by stakeholders ahead of and during the workshop were either not addressed or not clarified at all, leaving market participants with more legal uncertainty less than six months before the application deadline of the PRIIPs Regulation.