PRIIPs Q&As updated for Level 2 rules applying from 1 January 2023

On 21 December 2022, the European Supervisory Authorities (ESAs) published updated Q&As on the PRIIPs KID.

This follows a previous new version of the Q&As, published on 14 November 2022 (the November update) – see our summary here.

The Q&As cover issues under both the PRIIPs Regulation and the Level 2 rules made under it.

The Level 2 rules were set out in Commission Delegated Regulation (EU) 2017/653 (the KID Delegated Regulation). This, though, was amended by Commission Delegated Regulation (EU) 2021/2268 (the Amending Delegated Regulation), the vast majority of which took effect on 1 January 2023.

This meant, inevitably, that some of the Q&As in the November update related to requirements which were amended by the Amending Delegated Regulation and these would need to be revised or deleted in order for them to stay relevant after 1 January 2023.

The December Q&As, then, set out the required revisions or deletions.

Where questions are updated (or deleted in their entirety), these changes are made to reflect the updated version of the KID Delegated Regulation. Other than clarifying points where changes were necessary, then, the December Q&As do not provide additional guidance.

The amended Q&As are labelled within the document as having been updated on 21 December 2022 and can be found within the following sections / sub-sections of the Q&As:

• Performance scenarios
• PRIIPs with a recommended holding period (RHP) of less than one year
• Derivatives
• Multi-option products (MOPs)
• Methodology for calculation of costs
  • List of costs of investment funds (except transaction cost related questions)
  • Methodology set out in Point 21 of the Level 2 Annex VI (standardised costs)
  • Calculation of the summary cost indicators and
  • Presentation of costs.