Various respondents explained that digital solutions in the form of dynamic or personalised documents are possible within the current framework. However, most respondents highlighted that these solutions can only be a complement to paper or PDF based solutions, given the requirements in Article 14 of the PRIIPs Regulation. In view of this, various stakeholders argued that the existing "paper default" basis of the KID, and for example the need to evidence that a paper delivery is not preferred, is unnecessarily burdensome and not in line with the general move away from paper solutions. It was also noted that what may be described as "truly digital solutions" such a s those compatible with mobile devices, are not currently possible due to the structure of the KID specified by Article 6 of the PRIIPs Regulation.

The ESAs consider that there is a need to find a balance between quick, effective and innovative IT solutions, and at the same time ensuring a consistent level of consumer protection and clear communication of important information.

To support this a more fundamental assessment is needed of how regulatory disclosures and communications can work best for consumers in a digital, and in particular smartphone, age, rather than simply replicating paper via digital means. It is not appropriate for the ESAs to address detailed recommendations at this time; rather it is expected that this will be taken into account during upcoming more comprehensive reviews of PRIIPs, as well as other sectorial legislation.