Insurance Europe has raised concerns that a three to four month timeframe to implement the requirements for a Key Information Document (KID) for PRIIPs is unrealistically short. Based on current timings, there will be a period of three to four months between the publication of the final Regulatory Technical Standards, which will set out key elements of the KID, and the date the PRIIPS Regulation takes effect (on 31 December 2016). Insurance Europe points out that there are a number of reasons why the time period is too tight. For example, the final stage of defining risk indicators for different classes of products, cost indicators and performance scenarios are still the subject of consultation and until there is absolute certainty over the ultimate presentation and content of the KID, the final stages for preparing for its implementation cannot begin. Also, the aim of the PRIIPs Regulation is to ensure comparability between as many products as possible which requires important modifications to insurers’ IT systems, which takes time. Therefore, Insurance Europe strongly recommends a one year extension of the PRIIPs Regulation application date.

A link to the Position Paper is here