The Packaged Retail and Insurance-based Investment Products (PRIIPs) Regulation aims to ensure that retail investors are provided with accurate, fair and clear pre-contractual information to allow them to compare different investment products1. Should the premium for the insurance cover of insurance-based investment products be considered as a cost, the information in the Key Information Document (KID) would be distorted and a proper comparison of PRIIPs would not be possible.

In this context, Insurance Europe believes that it is of the utmost importance that the features of insurance-based investment products are properly taken into account within the PRIIPs KID. Insurance-based investment products have, per se, an insurance cover.