On 29 January 2016, Insurance Europe published its response to the European Supervisory Authorities' (ESAs) consultation on draft PRIIPs regulatory technical standards.  Insurance Europe reiterated its concern regarding the neat margin of time (3 to 4 months) available to insurers to implement Key Information Document (KID) requirements.  It also expressed the view that further criteria/guidelines were unnecessary in relation to complex PRIIPS products, as EIOPA was already obliged to develop guidelines under the Insurance Distribution Directive to address such/similar products.