The European PRIIPs Template (EPT) has been used to deliver the minimum set of required information for Packaged Retail Investment and Insurance Products (PRIIPs) since 2018, to standardise the transfer of PRIIPs regulatory data between financial market participants. Products in scope include investment funds (including UCITS and retail AIFs), insurance-based investment products (IBIPs), structured products and derivatives.
In September 2021, after several setbacks, the European Commission finally adopted its revised PRIIPs regulatory technical standards (RTS), with an effective date of 1 July 2022 (later put back to 1 January 2023). To accommodate these changes, FinDatEx’ PRIIPs technical working group published EPT V2.0 on 8 February 2022. Subsequently, however, EPT V2.1 was released to accommodate the different requirements of the UK market, and the Financial Conduct Authority’s (FCA) PRIIPs regime.
Here is what you need to know before transitioning to EPT V2.0 and/or EPT V2.1/V2.1UK.
What’s changing?
EPT V1 vs V2.0 (Click here for EPT V2.0)
Other than new identifier fields in line with other FinDatEx templates, the following changes have been made:
- Removal of UCITS KIID-type data fields, as UCITS in the EU will be producing PRIIPs KIDs instead
- Revised PRIIPs Level 2 RTS information requirements, including:
- uplifts to the SRI,
- signposted addresses for the past performance chart, and
- signpost to monthly-updated performance scenarios
- Changes to the introductory narrative
EPT V2.0 vs V2.1 (Click here for EPT V2.1)
Following FinDatEx’ consultation in August 2022, EPT V2.1 was released on 23 September to include an additional section required for the UK market. The key differences between EPT V2.0 and V2.1 are:
- A new section with fields specific to UK PRIIPs KIDs
- Revised version field to allow for a UK-only version (V2.1UK) as well as either an EU-only or EU and UK version (V2.1UK)
V2.1 also includes indicators for those fields that are relevant if completed only for the UK.
Who does it impact?
Fund Managers
All new versions of EPT are intended to be used for products sold from 1 January 2023.
PRIIPs providers such as fund managers (including UCITS and retail AIFs) will need to ensure they are ready and able to transition to EPT V2.0 or V2.1 well ahead of 31 December 2022 to allow time for those using the data to produce their own PRIIPs KIDs ready for 1 January 2023.
FE fundinfo recommends groups to provide EPT V1 in parallel with EPT V2.0/V2.1 for the duration of the transition period (i.e. from now until the end of December 2022).
Groups can also validate their regulatory data files through our Data Partner Portal prior to sending through their V2.0 and V2.1 templates.
Insurers and Fund Distributors
As a Fund Distributor currently taking Regulatory Data and Document Feeds from FE fundinfo, EPT V2.0/V2.1 files will be made available via our new Data Feed Portal.
A sample file will be made available to platforms and will be included as part of the product update. Please contact your usual FE fundinfo Account Manager for more information on how FE fundinfo is preparing your new EPT V2.0/V2.1 files.
Which template do I need to complete?
Funds distributed only in the EU will be able to complete either EPT V2.0 or V2.1.
Funds distributed only in the UK should complete EPT V2.1UK, ie V2.1 with only those fields relevant for the UK.
Funds distributed in both the EU and UK should complete EPT V2.1, including those fields in section 08 for the UK.
When do I need to complete the transition by?
While there are no explicit deadlines to transition from EPT V1.0 to EPT V2.0/V2.1, as the new templates are intended to be used for products sold from 1 January 2023, we recommend the transition to EPT V2.0/V2.1 to be completed ahead of 31 December 2022, thus giving sufficient time for the transmission of EPT data from product manufacturers to insurers who need to produce their own PRIIPs KIDs by 1 January 2023.
Do I need to continue to provide EPT V1.0?
EPT V1.0 should be completed up to the end of 2022 (i.e. 31 December 2022), as existing PRIIPs KIDs need to be monitored – and possibly revised – until then.
How we can help
FE fundinfo collects, validates and disseminates EPT data and PRIIPs documents, including the end-to-end production of new PRIIPs KIDs, through our regulatory data and document solutions and feeds. If you do not have an existing file arrangement with FE fundinfo, contact us now.
