Packaged retail and insurance-based investment products (PRIIPs)

Is it necessary to draw up and provide a PRIIPs KID in relation to a multi-option insurance-based investment product that is closed to new investment, but for which new underlying investment options are made available to existing investors, that were not available prior to 1 January 2018?

Example 1: Our Member carried out business on a Freedom of Services basis prior to 1 January 2018 and has a closed book of business to administer on a run off basis. The product in question is an insurance-based investment product under which the policy conditions enable the policyholder to switch the underlying assets to others permitted by the insurer. The product form remains available in other markets and consequently all the funds currently permitted by the insurer under the contract are available to all existing policyholders to exercise a switch under the policy terms wherever resident. In countries where the product is still marketed, the Member will either produce a KID or signpost in the Generic KID document to where the information can be found. Example 2: We have been closed to new business since 2013. We offer a range of unit linked products. From time to time we have to close internal funds, for example when the UCITS to which one of our internal funds links closes. We would like to make available a similar fund but are unsure whether this would create an obligation to produce a KID (since this fund was not available at the time the product was sold).