On 12 January 2016, Insurance Europe published a position paper calling for the implementation timeframe for the Regulation on KIDs for PRIIPs to be extended.  Insurance Europe noted that (a) there will only be three/four months between publication of the final KID rules and implementation of the PRIIPs Regulation and (b) the final stage of defining technical specifications, programming, testing and launching by the industry can only begin once there is certainty regarding the KID.  Insurance Europe advocates a one year extension of the PRIIPs Regulation application date.