The European Commission has adopted a delegated act supplementing the PRIIPS regulation in the form of the Regulatory Technical Standards for the production of the Key Investor Document or KID for PRIIPS.
Read the Regulatory Technical Standards
Above and beyond the production aspects of the KID for PRIIPs manufactures, UCITs funds, which do not need to produce the KID until 2019, will also be immediately affected by the Directive. This is because the PRIIPs who wrap their products will need to collect extensive amounts of data to produce their KIDs and in the case of Multi Option Products (MOPs) they will need to have easy access to the UCITs KIID documents. The consequence is that UCITs funds who might have thought that their deadline was in 2019 are quickly realizing that the still have a large an important obligation to meet this year.
At the same time, certain "UCITS only" groups could be tempted to anticipate the deadline of 2019 and produce from 2018 onwards the new KID for their own customers in order to avoid any confusion due to the co-existence of the KIDs and KIID's. They could in this way benefit from the first mover's advantage.