Key information document (KID), Reporting (Art. 40 PEPP)

Article 28(3)(f) of PEPP Regulation stipulates that the PEPP KID should contain in the section "What are the costs?" direct and indirect costs to be borne by the PEPP saver, presented by means of summary indicators of those costs and, to ensure comparability, total aggregate costs expressed in monetary and percentage terms, to show the compound effects of the total costs on the investment. The PEPP KID must include a single number as a total annual costs.Furthermore, Article 5 of Delegated Regulation (EU) 2021/473 stipulates that any costs and fees identified in the section ‘What are the costs?’ of the PEPP KID shall refer to actual incurred costs, incurred directly at the level of the provider or at the level of an outsourced activity or investment fund, including all related overhead costs.If borne by the PEPP saver, the ETF management fees should be included in the total annual costs. In the PEPP KID, the ETF management fees should be included in the total annual costs, and included in the PEPP KID. Where the ETF management fees is in a range, i.e., not fixed, the PEPP provider should consider the actual costs incurred from the previous year, following a method analogous to what we have seen in PRIIPs KID. These principles apply to all underlying assets.The ETF management fees, as any fees related to underlying assets, should be reported in the reporting template PP.52.01.33 under “investment costs" of the Commission Delegated Regulation (EU) 2021/897.​