Even though the association is in strong favour for a unified KID format, in the EU, JAC is “very concerned that the PRIIPs Regulation is due to apply as of 31 December 2016 and there is still no agreed form of Level 2 RTS”. And considers 3 potential options in regards to the PRIIPs legislation date:

Option a) The rejected RTS to be applied from 31 December 2016 but will be very swiftly revised, agreed politically without any meaningful consultation

Option b) The PRIIPs Regulation to be applied from 31 December 2016 with no RTS, and the RTS revised and amended with prudence, in good time.

Option c) Application of the PRIIPs Regulation to be delayed in order to allow sufficient time for the RTS to be settled. Allowing the industry to have sufficient time for review, comment, and act upon its contents.

The Association considers Option C to be the best course of action, being 2 and a half months away from the supposed deadline, giving different arguments why Option A and Option B would not be viable.

JAC concludes that the only reasonable option that would allow effective implementation of the PRIIPs Regulation, is for the application to be delayed by one year to the 3 January 2018. This would allow the level 2 RTS to be clarified, agreed, and amended while also allowing markets sufficient time to implement technical solutions and systems required to comply.

Read the full letter on JAC’s website