PRIIPs KID – Commission publishes its proposed Level 2 RTS

On 7 September 2021, the European Commission formally published its proposed Level 2 measures under the PRIIPs Regulation concerning the content and format of the Key Information Document (KID), along with the accompanying Annexes - these include templates which in-scope firms, such as UCITS ManCos, would be required to use.

The proposed RTS very largely follow the draft submitted to the Commission by the Joint European Supervisory Authorities (ESAs) back in February – for a summary of the contents of the ESAs' draft, please see our previous article.

The main change between the ESAs’ February draft and the Commission’s proposal is the date of application. As had been very widely anticipated, the Commission is proposing that the RTS should now apply from 1 July 2022 (rather than from 1 January 2022, as had originally been intended).

This, of course, brings their timing into alignment with both (a) the ending of the exemption under Article 32 of the PRIIPs Regulation, by which UCITS managers are not obliged to provide a KID and (b) the amendment to the UCITS Directive, which avoids a UCITS ManCo having to provide both a Key Investor Information Document (KIID) and a PRIIPs KID.

We will be reviewing the proposed RTS and will report on any further developments of significance in the near future.

For more information on the PRIIPS, please see our articles:

• PRIIPs developments in the EU: an update
• PRIIPs developments in the UK: an update

and our client note

• An FAQ on where things stand on PRIIPs KIDs for UCITS