EU RIS View - July 2025

Have you heard the latest? The second trilogue took place on 9 July. While there's still work to be done, there's clear momentum under the Council's Danish Presidency to push RIS forward. Here's what we know.

Commitment to Progress

Both the EU Parliament (EP) and the Council (under the Danish Presidency) have confirmed their commitment to quickly progress RIS. This is a positive signal, but as always, the devil is in the detail.

Value for Money (VfM)

Status: No agreement yet.

The Commission's simplification proposals were welcomed as a good starting point, but both the EP and Council have asked for concrete drafting and clearer explanations. For example, the EP has requested clarity on how the Commission's VfM simplification proposals for peer grouping (for investment funds and structured products) and EU supervisory benchmarks for insurance products would work in cases where multi-option products fall under both MiFID and IDD regimes.  As for the Council, it expressed its preference for as much clarity as possible in level 1 text (instead of extensive level 2). It also wants VfM reporting to function, as far as possible, by re-using existing data reported to national regulators and ESMA/EIOPA.

The Commission has agreed to prepare concrete drafting proposals on VfM by 15 September.

Inducements

Status: No agreement yet.

A ban is still off the table, with discussion focussing on the Council's proposed "inducements test" instead. The EP is pushing for either the removal of the Council's proposals for an "inducements test" or, if it remains, a clarification that it is to operate as a back-office test only. The Council appeared to agree that the test was intended to be conceived as a back-office tool (to be conducted before products are offered to clients). The Commission has agreed to provide concrete drafting proposals to clarify the test's scope and that it will be a back-office tool by 15 September.

The Council also expressed its preference for Member States to be able to gold-plate the inducements rules - to fully or partially ban inducements on a national level.

Client Categorisation

Status: No agreement yet.

The EP focussed on the sufficient experience and training criteria, noting that the current training parameter is poorly adapted to venture capital. It has requested more time to assess options in this area. The Council is open to consider new approaches, but pushed back on the Commission's recent simplification proposals for a one-off opt-up based solely on transaction size (e.g. a single transaction above EUR500k).

PRIIPs KID

Status: Some high-level agreement.

There's consensus on the need to simplify the KID, but the technical trilogues will hammer out the details. Key areas include the "products at a glance" section, possible layered disclosures and giving ESMA/EIOPA a mandate on KID drafting (in particular, in relation to investment scenarios and past performance). Notably, the EP and Council appeared to agree on no changes to the KID sustainability section for now. This will instead be revisited following the SFDR review.

The details will be thrashed out in technical trilogues.

Advisor Knowledge and Competency (K&C)

Status: Some high-level agreement.

The EP pushed for stronger sustainability-related knowledge. The Council pushed back on this, pointing out that the Commission proposals already increase the requirements around sustainability-related knowledge. A compromise was reached, under which the a 'strong' recital around sustainability-related knowledge will be prepared.

In relation to K&C overlaps under MiFID and IDD, the EP seeks a proportionality principle to be applied to small intermediaries distributing products under both MiFID and IDD (with training under both to be taken into account). The Council indicated an openness to this.

Again, the details will be thrashed out in technical trilogues.

What's Next?

On or before 15 September we're expecting to see concrete drafting proposals from the Commission on VfM and inducements. After that, the next trilogue is expected to take place at the end of September 2025.

For earlier background, you may want to read our earlier RIS Views which can be found on our RIS Hub Page. 

We'll keep you updated as we hear more.