EU RIS View: December 2025

Agreement reached!

The sixth round of RIS trilogues took place on Wednesday 17 December. Below, we provide a summary of the discussions, key outcomes and the current status of negotiations. Political agreement has now been reached on all topics. Detailed information is currently limited and our summary below is based on industry group updates and press releases from the Council and Parliament. Technical trilogues are expected to continue in early 2026 to agree the outstanding technical details. Publication of the legislation in the EU’s Official Journal is anticipated by the end of H1 2026.

Transitional period

Timing-wise, if the final rules were published in the EU’s Official Journal by the end of H1 2026, Member States would have to transpose by the end of H1 2028 and the earliest the RIS could apply would be the end of 2028. Under the same assumptions, the majority of the PRIIPs changes would apply end of 2027.

Value for Money (VfM)

Status: Agreement reached.

Sixth trilogue: The co-legislators agreed to take forward the European Commission’s (the Commission) dual approach proposal, i.e. using EU supervisory benchmarks under the Insurance Distribution Directive (IDD) and peer group benchmarking under MiFID II, UCITS and AIFMD. Firms must also assess whether total costs and charges are justified and proportionate.

The Parliament suggested a national-level approach to peer group benchmarking (i.e. peer groups limited to where the products are distributed), but both the Commission and Council advocated for an EU-wide approach. It seems that national-level peer group benchmarking will play a role, but the precise design and application remain unclear.

Inducements

Status: Agreement reached.

Sixth trilogue: The Council’s revised inducements test won out. This includes shifting from “quality enhancement services” to a requirement to provide “tangible benefits”. The revised rules strengthen the obligation on firms and advisers to act honestly, fairly and professionally in accordance with the best interest of its clients in mind. They must ensure that an inducement will lead to a “tangible benefit” for their client and that the inducement cost is published clearly and separately from other fees and commissions borne by the investor.

It seems to be that Member States will retain the ability to impose stricter inducement requirements at the national level, a position opposed by the Commission due to concerns over single market fragmentation.

The Council wanted to have a principles-based test at Level 1, with Level 2 limited to specifying what “tangible benefits” are and reclaim mechanisms under IDD. The Commission wanted broader Level 2 mandates for harmonisation and supervisory consistency. It is not clear yet what Level 2 measures will be introduced.

Client categorisation

Status: Provisional agreement reached in fourth trilogue.

Sixth trilogue: No further discussion. The co-legislators have agreed on a compromise position where a client could be categorised as an elective professional client where they meet two out the following three criteria:

1. One of three alternative criteria for transaction frequency: 15 transactions annually over the last three years; 30 transactions in the past year; or 10 transactions of at least €30,000 in unlisted companies in the past year; and
2. A wealth threshold of €250,000; or
3. The work experience or training/education criteria.

Customer journey

Status: Agreement reached.

Sixth trilogue: It was previously agreed that the MiFID client-level warning under the appropriateness test will be maintained, but firms will be free to design their own risk warnings as the ESAs’ Level 2 mandate to standardise these has been removed.

The core suitability rules will be broadly maintained. However, those providing advice will no longer be required to assess a client’s investment knowledge and experience for non-complex and cost-efficient products.

It is not clear what was agreed in relation to whether or not to remove risk warnings.

Undue costs

Status: Provisional agreement reached in fourth trilogue

Sixth trilogue: No further discussion. The co-legislators have chosen to take forward the Commission’s definition of due costs (i.e. being in line with disclosures in the prospectus and the PRIIPs Key Information Document (KID) and be limited to “necessary costs”), the Council’s approach on access to compensation (i.e. NCAs should address undue costs via the manager and investors in their supervisory activities, rather than via enforcement claims) and the Parliament’s proposal to impose a materiality/de minimis threshold for compensation. No mandatory fee cap has been imposed, which will be welcomed by the industry.

PRIIPs

Status: Agreement reached

Sixth trilogue: It was previously agreed that:

• past performance will be the default presentation in the KID, with a recital clarifying that future performance scenarios may only be used in exceptional cases;
• the “Product at a Glance” dashboard will be retained, but is restricted to essential information only, and the KID will still be limited to a maximum of three pages. The existence of financial guarantees will be excluded from this section;
• the comprehension alert should be deleted from KIDs;
• the sustainability section should be removed from RIS, with a recital clarifying that sustainability disclosures will be addressed through the ongoing SFDR review, see our client note on that here; and
• KIDs should be machine-readable, with reinforced mandates for the ESAs to support digital accessibility and improved data usability.

From a timing perspective, it has now been agreed that, for the PRIIPs changes, the revised rules will apply 18 months after the RIS is published in the OJ. PRIIPs KID information will need to be provided in a machine-readable format 30 months after the RIS is published in the OJ.

It is not clear what decisions have been reached on the PRIIPs online comparator and voluntary personalisation tool, both the Council and Commission were opposed to these. There is some industry concern about how burdensome these tools could be on firms, even if the personalisation tool were to be voluntary.

What’s next?

Technical trilogues will continue into early 2026 to agree the outstanding technical details. It is anticipated that the RIS text will be published in the OJ by the end of H1 2026. If the final rules were published in the EU’s Official Journal by the end of H1 2026, Member States would have to transpose by the end of H1 2028 and the earliest the RIS could apply would be the end of 2028. Under the same assumptions, the majority of the PRIIPs changes would apply end of 2027.

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

We will continue to monitor developments.