From UCITS KIIDs to PRIIPs KIDs: What Has Changed Since January 2023

by Martin Jones, Head of Document Solutions at FundSense

Goodbye UCITS KIID, Hello PRIIPs KID

Until the end of 2022, European retail investors in Undertakings for Collective Investment in Transferable Securities (UCITS) funds received the UCITS Key Investor Information Document (KIID). This short, standardised document formed a cornerstone of investor disclosure under the UCITS Directive.

That framework changed on 1 January 2023, when the exemption allowing UCITS to avoid Packaged Retail and Insurance-based Investment Products (PRIIPs) requirements expired. From that date, all UCITS funds marketed to EU retail investors have been required to produce a PRIIPs Key Information Document (KID), aligning them with other retail investment products covered by the PRIIPs regime.

The transition was designed to improve comparability and consistency across the retail investment landscape. However, the implementation has been far from static. Since 2023, the European Supervisory Authorities (ESAs) have issued multiple clarifications and consolidated Q&As, which have influenced how fund managers must calculate and present performance scenarios, costs, risk disclosures, and other essential disclosures.

The UK Position

Following Brexit, the UK “on-shored” the PRIIPs rules but extended the UCITS exemption: UK-domiciled UCITS funds may continue providing UCITS KIIDs to UK retail investors until 31 December 2026.

At the same time, HM Treasury has established the legislative foundation for a new, UK-specific retail investment disclosure regime — the Consumer Composite Investments (CCI) framework — with the Financial Conduct Authority (FCA) now developing detailed rules, consultations, and product information requirements to accompany it.

Key Changes and Clarifications Since 2023

Performance Scenarios

In response to widespread criticism that the original PRIIPs scenarios were overly optimistic, the revised Regulatory Technical Standards (RTS) under Regulation (EU) 2021/2268 introduced a new performance scenario calculation methodology, effective from 1 January 2023.

The ESAs’ consolidated Q&A (most recently updated in May 2025) provides further detail – for example:

• Clarifying how to calculate stressed volatility

• How percentile values must be selected

• How one-year holding periods should be treated

These refinements, outlined in Q&A items 24–26, are designed to reduce the risk of misleading projections and enhance comparability across funds.

Costs and Charges

Transaction costs, anti-dilution levies, and implicit costs must now be disclosed more transparently. The KID now uses a Reduction in Yield (RIY) figure to show investors the estimated impact of total costs on their returns over varying holding periods. The ESAs’ May 2025 Q&A (Question 6) provides detailed clarification on cost calculation methodology, helping to reduce inconsistencies across EU Member States.

Past Performance

Unlike the UCITS KIID, the PRIIPs KID no longer includes a past performance chart directly. Instead, it provides a mandatory signpost directing investors to another source — often a webpage — where historical performance data is available. This requirement was introduced in Regulation (EU) 2021/2268 and is further supported by the ESAs’ Q&A clarifications.

Ongoing Q&A Updates

The ESAs’ have continued to update their consolidated Q&A, with significant versions released in:

• December 2023 – covering multi-option products (MOPs), manufacturer responsibilities, and related topics.

• May 2025 – the most comprehensive update to date.

Key topics addressed include:

• Performance scenario methodology

• Summary Risk Indicator (SRI) classifications

• Treatment of derivatives and structured payoffs

• Data disclosure for multi-option products

• Signposting and hyperlinking requirements

The Knock-On Effect: The European PRIIPs Template (EPT)

While the PRIIPs KID is investor-facing, distributors and data recipients require a structured, machine-readable format to process and share data. This is the role of the European PRIIPs Template (EPT).

Who Maintains It?

The EPT is maintained by FinDatEx (Financial Data Exchange Templates) — a collaboration between European trade associations (including EFAMA, BVI, and ABI) with the aim of standardising fund data exchange across Europe.

Latest Version

The current version is EPT v2.1, released in October 2022. It aligns with the revised PRIIPs RTS and incorporates:

• Updates for cost disclosures

• The new performance scenario approach

• UK-specific data fields to account for post-Brexit divergence

Many distributors now require EPT v2.1 submissions for platform access. Incomplete or inconsistent data submissions may impact product availability.

Industry Impacts and Challenges

Operational Disruption

The 2023 implementation required many firms to rebuild data pipelines to accommodate the new RTS and ongoing Q&A clarifications. Continuous regulatory updates demand regular adaptation.

Data Consistency

PRIIPs KIDs and EPTs must align precisely. Any discrepancy between what an investor sees in a KID and what the distributor receives via the EPT may trigger regulatory scrutiny or raise distribution concerns.

Automation and Scalability

Manual document production and data delivery are increasingly unsustainable. Firms are increasingly investing in:

• Automated data aggregation and document generation tools

• Built-in audit trails and validation workflows

• Scalable solutions that support multi-jurisdictional compliance

Distributor Pressure

Distributors and fund platforms now expect timely, validated, and accurate EPT submissions. Errors or delays can directly affect a product’s visibility or availability to retail investors.

Looking Ahead: 2025 and Beyond

Convergence of Disclosure Standards

The PRIIPs KID, EPT, and European MiFID Template (EMT) are becoming progressively interconnected. Firms that integrate these disclosures into a unified, automated framework will minimise duplication and strengthen data governance.

Future RTS Amendments

The ESAs continue to evaluate the effectiveness of the PRIIPs framework. Additional RTS updates and expanded Q&A guidance are likely as the industry raises further questions.

Conclusion

Since 1 January 2023, the transition from the UCITS KIID to the PRIIPs KID has transformed how European funds communicate performance, risk and cost to retail investors.

Key developments include:

• A revised performance scenario methodology and enhanced cost disclosure framework

• The removal of past performance charts from the KID itself

• The evolution of EPT v2.1 as a vital data delivery mechanism

For firms treating this purely as a compliance exercise, the transition has been complex and resource-intensive. Yet for those investing in strong automation, data integrity, and robust governance, the PRIIPs regime presents an opportunity — not just to meet regulatory obligations, but to enhance operational resilience and build competitive advantage in an evolving disclosure landscape.

About FundSense

FundSense delivers intelligent automation for the asset management industry, helping firms simplify and strengthen their disclosure processes across global regulatory regimes.

From UCITS KIIDs and PRIIPs KIDs to the upcoming UK CCI framework, FundSense enables seamless data integration, automated validation, and compliant document production — ensuring accuracy, transparency, and efficiency at every stage.

By combining regulatory expertise with automation technology, FundSense empowers asset managers to move beyond compliance and turn evolving disclosure obligations into a source of operational resilience and strategic advantage.

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To learn more, visit fundsense.io or contact our team to discuss how FundSense can help future-proof your disclosure environment.