PRIIPs: Postponement?

02.11.2016 - The EU Regulation No. 1286/2014 of the European Parliament and the Council on key information documents for packaged retail and insurance-based investment products (PRIIPs) became effective at the end of 2014. Therefore, as of the 1st of January 2017 manufacturers of packaged retail and insurance-based investment products are under certain circumstances obliged to provide so-called key information documents. Packaged retail and insurance-based investment products are especially funds.

For open and closed end retail funds under the KAGB, there is a transitional period until the 31^st of December 2019 to prepare and provide the key information documents for investors.
For open and closed end special funds under the KAGB, which are also offered to semi-professional investors, it is possible to provide the key information documents voluntarily. In this case there is also a transitional period until the 31^st of December 2019.
For old closed end funds, which are not subject to the KAGB, there is no transitional period, even when the product has been removed from active sales long ago.

The European Commission will presumably postpone the obligation to provide PRIIPs-KIDs by one year to 1st of January 2018. The announcement of the postponement is expected to be made on the 9th of November 2016. In case there will not be an exception for old closed end funds, there will be enough time for the fund management to comply to the regulatory requirements cost-effectively and in a sustainable manner. The goal is to achieve a purposeful implementation management to meet the requirements adequately and legally secure in a short amount of time.

Our team of legal advisors and management consultants, including public auditors, would be pleased to be of assistance in order to discuss an appropriate and audit-proof implementation program with you.