The Association of Mutual Insurers and Insurance Cooperative in Europe (AMICE) have called on the European Parliament and the Council of the EU to object to the Commission Delegated Regulation adopted by the European Commission in mid-July, laying down regulatory technical standards (RTS) with regard to the presentation of key information documents (KIDs) for packaged retail and insurance-based investment products (PRIIPs) (the Delegated Regulation). The Delegated Regulation is currently being considered by the European Parliament and Council. If neither objects, it will apply from 31 December 2016. AMICE cautions that only an objection will provide the Commission and the European Supervisory Authorities the time to resolve the outstanding issues with the RTS.

AMICE supports the objectives of the PRIIPs Regulation of increasing consumer protection through the use of a standard KID, but it is extremely concerned over a number of outstanding issues with the RTS which is now in its final approval stage (these issues have also been raised by a number of stakeholders and reported in the July edition of the Arthur Cox Insurance Regulatory Update). AMICE cites examples of such issues: the presentation of the ‘biometric risk premium’ for insurance products as part of overall costs related to PRIIPs rather than on a stand-alone basis; the risk categorisation of insurance products and the calculation of credit risk; and the treatment of multi-option products and their underlying funds.

A link to the AMICE letter is here