Insurance Europe has responded to a discussion paper by the joint committee of the three European supervisory authorities on key information documents (KIDs) for packaged retail and insurance-based investment products (PRIIPs). The KIDs are designed to help retail investors to better understand and compare PRIIPs across the EU.
Insurance Europe underlined that a KID should contain accurate, fair, clear and not misleading pre-contractual information that is relevant for that specific product. It explained that it is of utmost importance that the specific features of insurance-based investment products are taken into account appropriately when considering the presentation and content of the KIDs. Unlike other PRIIPs, insurance-based investment products provide for additional benefits and protection. Hence, KIDs for insurance-based investment products should contain information tailored to the features of such a product.
Insurance Europe also raised concerns about the potential duplication of some pre-contractual information that will be provided to retail investors, as products can be subject to several pieces of EU legislation, such as Solvency II, the revised Insurance Mediation Directive (IMD 2) and the PRIIPs Regulation.
The responses to this consultation will be considered by the European supervisory authorities when developing draft regulatory technical standards on the content and presentation of the KIDs for PRIIPs.