ALFI responds to ESA consultation on PRIIPs KID

19 December 2019 | Statements and Position Papers  

ALFI responded to the consultation of the European Supervisory Authorities (ESA) concerning amendments to the PRIIPs KID.


ALFI strongly opposes the prospect of having to produce UCITS KIIDs for professional investors when the exemption for UCITS expires. The content of the UCITS KIID was primarily designed for retail investors and not for institutional investors. Professional investors need more detailed and customised information that is provided to them through other tools. It would also entail substantial efforts and costs for asset managers to maintain and produce two different types of documents. This would create much confusion to investors.


Moreover, ALFI is of the view that the PRIIPs framework should establish a level playing field between all types of PRIIPs. As a result, where possible, in particular for PRIIPs within the same risk category, the required information should be the same across those products. If the level playing field is not extended to all categories, there is a risk that the investor cannot compare all different types of PRIIPs.


Read the response.