Insurance EuropeInsurance Europe
Position Paper
PRIIPs provisions that require clarification at level 3

Insurance Europe's paper sets out issues that still require clarification through the Level 3 guidance for the Packaged Retail and Insurance-based Investment Products (PRIIPs) Regulation.

The paper addresses the following:

  • It calls for flexibility in the application of PRIIPs to multiple investment options (MOPs), annuities and funeral contracts
  • It calls for a clarification of when warnings about additional distribution costs should be included
  • It suggests a stop-gap measure allowing additional disclaimers explaining the performance scenarios to be included in the key information document (KID), in line with the approach already taken by the UK's Financial Conduct Authority. 

Insurance Europe also emphasises that these interim measures would not solve the underlying problems with the PRIIPs KID, which will need to be addressed through the full review of the Regulation. Furtheremore, it urges policymakers to group together any changes to the KID and allow for appropriate phase-ins to reduce the compliance risk for insurers. 

Published 12 June 2018
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William Vidonja
William Vidonja
Head of conduct of business
Emma Coles
Emma Coles
Policy advisor