Call for Input: PRIIPs Regulation – initial experiences with the new requirements

Read FS19/1 (PDF)[2]

The PRIIPs Regulation requires certain firms to prepare and provide investors with standardised key information documents (KIDs). It aims to improve consumer understanding and outcomes by standardising the disclosures retail investors receive, giving them the ability to compare competing products.

We asked those who are producing, advising on, or distributing PRIIPs (and preparing and providing KIDs), and consumers now using KIDs to share their initial experiences of the requirements. We asked questions around the scope of the PRIIPs Regulation, and around the content of KIDs. 

The Call for Input[3] (CfI) generated a high level of interest. We received 103 responses from firms, trade bodies and consumer organisations. In this Feedback Statement:

• We summarise responses received to the CfI.
• We set out our responses to the feedback received.
• We outline options to address areas of concern.

We believe that the concerns raised by respondents to the CfI about uncertainty of scope of products needing to comply with PRIIPs and the unintended effects of compliance requirements are particularly serious and may risk causing consumer harm if not addressed.

Who this applies to

This Call for Input will be of interest to:

• consumers and their representative bodies
• those who manufacture PRIIPs and those who advise on or distribute PRIIPs. 

This includes, but is not limited to the following firms: 

• issuers of securities that are classed as PRIIPs (including businesses that do not require Part 4A authorisation under FSMA)
• life companies
• discretionary investment management firms
• firms providing services in relation to insurance-based investments
• fund managers
• wealth managers
• stockbrokers and other firms that provide advice to retail clients on funds, structured products and derivatives
• financial advisers
• firms operating retail distribution platforms

Next steps

We will continue to work closely with the European Supervisory Authorities and the European Commission through 2019, subject to the nature of the UK’s relationship with the EU. We do have significant concerns about potentially conflicting requirements or lack of clarity about scope of application of PRIIPs requirements. We will consider the extent to which domestic interpretive guidance could mitigate our concerns around performance scenarios, Summary Risk Indicators and the scope of the PRIIPs legislation.