Insurance Europe has evaluated the draft RTS determining the presentation and content of KIDs under the PRIIPs regulation submitted by the ESAs (see above). It judges them to be inappropriate for insurance-based investment products and that, if implemented, they would mislead consumers. It claims that consumers would be misled because the RTS do not adequately explain insurance-based investment products and so consumers would not be able to make a meaningful comparison between products. Because of the problems with the draft RTS, Insurance Europe has called for a one-year extension to the PRIIPs application date so that there is sufficient time to program, test and launch the KID correctly. (Source: Insurance Europe seeks adjustment to PRIIPs KID timeline)