4.9.1 Application of the requirement in Article 13(4) of the PRIIPs Regulation in the case of regular savings plans

In response to question 45 in the consultation paper, the majority of respondents were clearly in favour of changing the PRIIPs Regulation. It is argued that the established market practice under the UCITS regime on the basis of the Q&A is effective and provides retail investor s with the relevant information, while not overloading them. In contrast, the approach required for PRIIPs is not considered feasible for mass markets and may disrupt existing saving plans that are often used as long-term savings products. It was also noted that regular saving plans for UCITS are very common in Italy, Spain and Germany and that these markets would be heavily affected if no change is proposed before the expiry of the UCITS exemption.

Taking into account this feedback, the ESAs recommend a change to the PRIIPs Regulation to address this issue. The ESAs recommend, as a preferred approach, a change to Article 13(4) in line with the UCITS Q&A, which could be drafted as follows: