The problem with PRIIPs – our response to the FCA’s call for input


Scott Holmes

Scott Holmes

Audit Partner


We recently responded to the FCA’s call for input on the Packaged Retail and Insurance-based Investment Products legislation (PRIIPs). The legislation came into force in January and brought with it seismic change to disclosure requirements for investment products aimed at retail investors. 

The legislation has been hugely controversial in the financial services industry. It was meant to aid comparability across investment products and ensure that investors are better informed as to risks, performance and costs, however, there is a broad consensus that PRIIPs has failed in this objective and that the measures of risk and performance can be downright misleading.

What is PRIIPs?

PRIIPs covers retail investment products such as investment trusts, venture capital trusts and real estate investment trusts. Each of these products is required to produce a Key Information Document (KID) to a standard format. Producing these documents requires complex calculations which are set out in the legislation.

Our view

At Johnston Carmichael, our Financial Services team have produced more than 20 KIDs for clients across the whole range of retail investment products. This significant body of experience has informed a response which echoes industry concerns and also considers the key practical issues we have encountered, covering both existing products and new fund launches. You can read our full consultation response by clicking on the link below.

Consultation response to FCA call for input on PRIIPs regulation 28 September 2018

Next steps

The FCA are now considering consultation responses and will publish a report in early 2019.