Most stakeholders criticised the approach taken to the review and did not consider that the proposals made by the ESAs would resolve the issues that have been identified with the current KID. With reference to Article 33 of the PRIIPs Regulation, respondents argued first for a comprehensive review of the PRIIPs (Level 1) Regulation instead of seeking to address issues within the PRIIPs Delegated Regulation.

There was also agreement amongst respondents that there should be a single round of regulatory changes rather than a graduated approach. The vast majority of respondents therefore considered that it is preferable to align any changes with the expiry of the exemption for UCITS at the end of 2021. However, several respondents, mainly consumer associations, saw merit in implementing the changes as soon as possible. In addition, some respondents from the securities sector argued for the need for a transitional period for existing PRIIPs.

As set out in Sections 1 and 2 above, the ESAs have proceeded with proposed amendments to the PRIIPs Delegated Regulation, which are considered to be a basis for improving the KID. Nonetheless, the feedback received and analysis conducted has led the ESAs to conclude that it is relevant to recommend specific amendments to the PRIIPs Regulation at this time.