PRIIPS

The objective of the PRIIPS regulation is to improve the protection of retail investors in the field of financial services so that investors would be able to choose their financial products based on clear and reliable information. The PRIIPs Regulation and the elaborating level 2 measures prescribe in particular the information to be given on the investment products.

A retail investor means an investor other than a professional client under the MiFID. Professional and non-professional clients are defined in chapter 1, section 23 of the Act on Investment Services (747/2012, in Finnish).

The PRIIPs Regulation applies to service providers producing and offering PRIIPs products to retail investors. These include banks, insurance companies, management companies and alternative investment fund managers and bond issuers.

Service providers must prepare a Key Information Document (KID) for each product. The KID provides information on the key features of the investment product as well as related risks and costs. The document must contain information on, among other things, whether the product can give rise to losses and on how complex the product is.

A KID must be prepared for the following products, for example:

• alternative investment funds 
• structured retail market products (including structured deposits)
• insurance policies used for investing and saving
• investment funds.

Language requirements for Key Information Documents

In accordance with the PRIIPs Regulation, the key information document shall be written in a language which is an official language used in the member state or another language accepted by the competent authorities.
The FIN-FSA’s view is, that the key information documents for products offered in Finland should be made available in Finnish or Swedish.
In the FIN-FSA's opinion, the key information document could be made available in English if the following prerequisites are met:

1. The distributor of the product must ensure that the customer can understand the key features and risks of the PRIIP in accordance with the PRIIPs Regulation, and
2. The service provider must comply with other regulatory requirements, for example regarding the assessment of the target market of the product (product governance) and requirements on customer-specific assessment of appropriateness.

If a PRIIP is being promoted in the official language of a member state, the key information document must be prepared in a comparable language. Hence, the use of an English-language key information document in Finland is only possible if the product is not promoted in Finnish or Swedish.
The translation of a key information document may also be made by a distributor of the product. However, the translation of the key information document must be published on the website of the manufacturer of the PRIIP, and the manufacturer is liable for the accuracy of the translation.

Application and timetable

The application of the Regulation began on 1 January 2018.

The transition period under PRIIPS regulation for UCITS funds came to an end on 1 January 2023.

The PRIIPS Regulation originally included a transitional provision for UCITS funds and alternative investment funds provided to non-professional clients. According to the transitional provision, there was no need to prepare a Key Information Document under the PRIIPS Regulation on these types of funds. However, they have been subject to an obligation to prepare a Key Investor Information Document under UCITS regulation until 31 December 2022.

Submission of Key Information Documents to the Financial Supervisory Authority

According to the Act on the Financial Supervisory Authority (878/2008, Section 37 c) the developer of a packaged investment product or the product vendor shall submit the key information document drawn up for the product as referred to in the KIDs for PRIIPs Regulation to the Financial Supervisory Authority for its information, no later than when the distribution of the product in Finland begins.

Submission address:

PRIIPS-KID(at)fiva.fi.

A Key Information Document submitted to the Financial Supervisory Authority (FIN-FSA) must be a text-form PDF file (not scanned, not an image).
A Key Information Document must be named so that the developer of the PRIIP product in question, the name of the PRIIP product and its risk indicator are apparent from the name of the PDF document. These three items of information should be separated by an underscore character. For the risk indicator, only a number (1-7) is added to the name.

Model example: Fund management company X_Investment Fund Finland_5