On 5 December 2025, the European Supervisory Authorities published an updated consolidated version of the Q&A on the PRIIPs Key Information Document (“KID”). This consolidated document brings together guidance issued by the European Commission and by the European Supervisory Authorities, covering both the interpretation of Union law and the practical application of the PRIIPs Regulation and its Delegated Acts.
This consolidated document incorporates the clarifications and technical adjustments introduced during 2025 and integrated into the Q&A up to December 2025.
It primarily clarifies three areas of the PRIIPs framework that are of particular practical relevance for PRIIP manufacturers, namely the monitoring of the Market Risk Measure and the Summary Risk Indicator, the calculation of performance scenarios across different holding periods, and the calculation of summary cost indicators.
The main clarifications introduced by the consolidated Q&A are summarised below.
Market Risk Measure and Summary Risk Indicator
The consolidated Q&A clarifies how the Market Risk Measure (the “MRM”), which feeds into the Summary Risk Indicator (the “SRI”), must be monitored and reviewed in practice.
A change to the MRM class does not apply immediately when the calculated risk level fluctuates. A new MRM class applies only if it has been observed for the majority of reference points over the preceding four-month period. Where this threshold is not met, the existing MRM class must be maintained.
This rule also applies at the time of the annual review of the KID. A PRIIP manufacturer may not apply a new MRM class in advance merely because the risk level is expected to change. Only sustained changes observed over the four-month period may justify an update.
The consolidated Q&A also recalls the ongoing monitoring obligation. Where a change to the SRI is identified, a revised KID must be published, even if the KID has been reviewed less than twelve months earlier.
Performance scenarios and holding periods
The December 2025 consolidation confirms that the methodology applicable to a performance scenario must always be determined by the effective holding period concerned, including where intermediate holding periods are presented. Where the holding period is one year or less, the parameters applicable to a one-year holding period must be used. Different parameters apply only where the holding period exceeds one year.
The consolidation also clarifies that redemption features or maturity values do not, in themselves, constitute capital protection. In the absence of unconditional capital protection, unfavourable scenarios must continue to reflect the possibility of losses, regardless of any redemption value at maturity.
More generally, these clarifications are intended to ensure that performance scenarios are calculated consistently across products and holding periods and to limit divergent methodological approaches.
Calculation of the summary cost indicators
For the purpose of presenting costs, point 90 of Annex VI of the PRIIPs Delegated Regulation requires that cost information be shown on the basis of a standardised investment amount of EUR 10,000 in order to ensure comparability between PRIIPs.
The consolidated Q&A clarifies that entry costs must be included in this reference amount.
PRIIP manufacturers should take these clarifications into account when reviewing their KIDs and their ongoing monitoring processes.
BSP remains available to assist with any questions relating to the interpretation and practical application of the PRIIPs framework and the consolidated Q&A.
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