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Version date: 30 June 2020 - onwards

4.5 Use of illustrative scenarios

The feedback regarding the use of illustrative scenarios combined with probabilistic performance scenarios was consistent in terms of respondents arguing against these proposals with the main arguments cited being the following:

Displaying both types of scenarios will create an overload of information;

Investors probably will not understand the differences between the two methodologies and will be confused;

Additional scenarios cannot be fitted into the KID (due to the three pages limit).

The consumer testing results also did not provide evidence to support the use of illustrative scenarios together with probabilistic performance scenarios.

In terms of the option to replace the probabilistic performance scenarios with illustrative scenarios, the views of those that responded to this question were more mixed. There also appeared to be some different understandings of the meaning of illustrative scenarios. On the one hand, a significant proportion of respondents in favour of the approach underlined that this type of approach has worked well for structured UCITS for numerous years. It is argued that these scenarios are better suited to retail investors because they do not give the impression that they are seeking to predict the future. On the other hand, numerous respondents that were critical of the proposal highlighted that the choice of scenario is essentially arbitrary. This, it was claimed, allows for the approach to be misused and makes it difficult to compare between PRIIPs. For these respondents, the benefits of such a change in approach did not outweigh the implementation costs of replacing the existing methodology.