Disclosure (Art. 26 – 33, 35 - 39 PEPP)

We would like to clarify the interpretation of Annex III, Part 3, Section 29 which provides that, “where necessary, these amounts may be calculated as the average total annual costs over the term of the PEPP contract. The calculation of the compound effect of the costs shall be based on a 40 years’ accumulation period, based on monthly contributions of EUR 100 and on the projected accumulated capital in the best estimate scenario.” Should this 40-year methodology be always applied when presenting total annual costs in Section 4 of the KID PEPP (“What are the costs”), particularly in the subsection showing total annual costs expressed in monetary and percentage terms or shall the costs in this column be calculated as total annual costs incurred and chargeable within 12 months, expressed both in monetary terms and as a percentage of the projected accumulated capital after 12 months, based on monthly contributions of €100 in the best estimate scenario? If the costs shall be calculated as total annual costs incurred and chargeable within 12 months, is it allowed to base the calculation solely on the first 12 months of saving, i.e., with total contributions amounting to 1,200 euros at the end of the 12 months?