On 8 February, FinDatEx – the Europe-wide industry initiative set up to deliver standardised templates for regulatory data transfer – published its updated European PRIIPs Template (EPT) to accommodate the changes coming in with the revised regulatory technical standards (RTS) and the ending of the exemption that allows UCITS funds to continue to issue UCITS KIIDs.
After several delays to both the revised RTS and the end of the UCITS KIID exemption, they are now due to take effect at the end of this year, after which all packaged investment products available to retail investors in the EU will need to publish and maintain a PRIIPs KID. Institutional share classes of UCITS funds will be able to publish either a UCITS KIID or a PRIIPs KID, as they fall outside the reach of the PRIIPs Regulation and the two documents will be equivalent.
When should groups start transitioning across from EPT v1 to v2?
While the EPT v2 is expected to be used for all PRIIPs sold from 1 January 2023, the FinDatEx working group is yet to determine when groups should start to transition across from v1 to v2. This will inevitably be some time before the end of 2022, as fund groups will need to supply the data for insurance products and funds of funds that invest in them, so they can produce their own KIDs in time for the deadline.
There is also likely to be a period of parallel running, so “legacy” PRIIPs KIDs can be maintained until the end of the year, while providers are preparing for the new rules.
What changes have been made?
Other than new identifier fields in line with other FinDatEx templates, EPT v2 has naturally dropped the fields from v1 for UCITS-type data, and the additional information requirements in the revised RTS have been incorporated. These include whether the summary risk indicator (SRI) has been adjusted upwards, and the signposted addresses for the past performance chart and monthly-updated performance scenarios.
There are also some new fields related to autocall structured products, and there has been some tidying up of field names and descriptions to take account of the RTS changes.
But probably the most important changes are in the introductory narrative of the new EPT:
- Currently, multi-option products (MOPs) that invest in a UCITS fund may refer to the UCITS KIID as the specific information document (SID) on that investment option; FinDatEx states that a PRIIPs KID published by a fund group will in future also be able to double as a SID.
- All the information on the EPT (eg the recommended holding period, costs, etc) should relate to the investment fund, not the insurance product that may invest in it.
- As with other FinDatEx templates, there are different sections on the EPT v2, not all of which need to be updated at the same time. In this case, the four sections are for narratives, costs, additional information for structured products, and additional data for German MOPs; if a whole section is unchanged, it should be left blank and all the validation rules in that section, such as for mandatory fields, should be ignored.
- The data in the EPT should match the latest published fund KID, and the update date should be the same as for that KID (apart from any additional information for German MOPs).
Preparing for the transition
All in all, the changes from EPT v1 to v2 make sense and revolve around either the disappearance of UCITS KIIDs for retail funds or the additional specific data requirements in the new RTS, but it would be good to have a reasonably long parallel running period before the end of the year, so those fund groups that already supply EPT data can get used to these changes without worrying about meeting the deadline.
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