General information in relation to the annual review of PRIIP-KIDs (UCITS)

According to Regulation (EU) No 1286/2014 and the Commission Delegated Regulation (EU) 2017/653, the content of the KID needs to be brief, clear and easily understandable, in order to enable the investor to make an informed decision.

Consequently, the KID needs to summarise the relevant key points of the respective investment policy of a sub-fund.

The objective should always be a condensed description of the investment policy and strategy in a clear and understandable language for a retail investor (not a copy of the investment policy from the sales prospectus).

All positions which entail important risk profiles must be mentioned, even in cases where those investments are ancillary.

A brief description of the secondary investment policy must be provided, and it needs to be ensured that the secondary policy does not take up more space than the main policy; a proportionate approach should be adopted.

Information which merely overloads the KID needs to be disregarded from the KID and reflected only in the prospectus.

In relation to the general annual update requirement of the KID, whilst UCITS are not bound by a specific yearly timeline (i.e. the twelve-month deadline applies from the date of the last version of the KID), the CSSF recommends to prepare and submit such general update within 35 business days after 31 December as a good practice, in order to facilitate the CSSF’s supervisory process of KIDs.

Please inform the CSSF of the effective date for any share classes that are dormant, no longer actively distributed, liquidated, or otherwise inactive.

The CSSF reserves the right to periodically review submitted KIDs and take action in case it notices discrepancies between the KID and the prospectus, or late submissions.