ESMA · ESMA_QA_2645 Question Rejected

Intent to Present Future Performance in Percentage Terms in Robo-Advisory App – Compliance with MiFID II (incl. Article 44) and PRIIPs

Regulation
Packaged Retail and Insurance-based Investment Products Regulation (PRIIPS) Regulation (EU) No 1286/2014
Article
Additionally MiFID 2 - article 44
Topic
Disclosures
Submitted
2025-09-17
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Question

We are currently exploring the possibility of presenting future performance in percentage terms within our robo-advisory application. The app provides automated investment recommendations based on client profiling and risk tolerance, and may in the future include visual projections of potential returns. These projections would be expressed as percentages, clearly labeled as hypothetical, and accompanied by appropriate disclaimers and risk warnings. The format would follow the structure and methodology of performance scenarios as outlined in Annex IV of the PRIIPs Regulation. In this context, we would like to clarify: Is it permissible to present future performance in percentage terms if the format aligns with the performance scenarios described in PRIIPs Annex IV? Would such a presentation be compliant with Article 44 of MiFID II, particularly in digital interfaces?
No answer published yet.
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