German Banking Industry CommitteeCapital market

Comments Review of the PRIIPs Regulation in the context of Retail Investment Strategy Proposal of the European Commission


On 24 May 2023, the European Commission published a draft for the amendment of the PRIIPs Regulation (PRIIPs Draft) within the framework of its Retail Investment Strategy (RIS). The German Banking Industry Committee (GBIC) welcomes the intention of the European Commission to also revise the PRIIPs Regulation within the framework of the RIS. In doing so, some of the existing weaknesses of the regulatory requirements are to be eliminated so that the Key Information Documents (KIDs) can form a better basis for the investment decisions of retail investors.

In its draft regulation, the European Commission proposed some positive changes, such as the priority of the electronic provision of KIDs (this creates a synchronisation with MiFID II) or the exemption for bonds with a make-whole clause to be out of scope of application of the PRIIPs Regulation.

Nevertheless, we would have liked the European Commission to propose further improvements in order to strengthen confidence in the capital markets and thus promote investments by retail investors in particular. For example, the European Supervisory Authorities (ESAs) had proposed several further improvements in their final report for the PRIIPs review (2022), which were not taken into account in the PRIIPs Draft. Overall, the proposals in the PRIIPs Draft are not very concrete and it would be desirable not to outsource too much to the level 2. Improvements are therefore urgently needed in the further legislative process.

In order to achieve the goal pursued with the PRIIPs review of significantly improving KIDs, further points in particular should be introduced into the upcoming legislative process.