As we wrapped up 2021, we saw several important regulatory updates on the European, UK, and Swiss level that affect PRIIP manufacturers.
The latest update is the official publication of the Commission Delegated Regulation (EU) 2021/2268 to the Official Journal of the European Union on 20 December 2021. This completes the final step necessary for the complete legislation of the EU PRIIP KID regulatory technical standards amendments that were proposed in the past year.
The regulation will enter into force starting from 01 July 2022. It amends and replaces the existing RTS version (2017/653), which has been in place since the start of the EU PRIIP requirements in 2018 and will cease to apply on 30 June 2022.
If you have carefully followed our previous newsletters or the regulatory developments, you might be asking yourself if the above date is correct, given the fact that the UCITS / AIFs transition period in relation to the PRIIP requirements was recently extended to the end of 2022.
You are not mistaken and both dates are correct. As a short summary consider the following:
- As mentioned above, the amendments to the EU PRIIP RTS (i.e. model and structure of the PRIIP KID) shall be implemented starting from 01 July 2022. This means all manufacturers, providing a RPIIP KID for their EU retail clients, shall adhere to the new requirements starting from 01 July 2022.
- This does not diminish the right of the UCITS and AIFs manufacturers targeting retail clients in EU. Those are exempted from a PRIIP KID obligation as part of the extended transition period until the end of 2022, provided they produce and provide a KIID (Key Investor Information Document) as a replacement of the KID
A change to the enforcement date of the new RTS updates is not proposed, so currently it is also not expected. This development has been expected by cleversoft and we have thus prepared for an implementation of the required changes as part of our cleversoft standard PRIIP service to support the new requirements by 01 July 2022.
For all of our clients with dedicated PRIIP solutions, our team is eager to support you with the required preparation to ensure they can meet the new European requirements before the cut-off date.
Curious how we can help? Talk to our team and let's sort through the legislative changes together.