Could you confirm if manufacturers of insurance-based investment products are allowed to signpost to KIDs produced by fund managers instead of proper SIDs in their IBIP MOPs? What happens when the RHP

For insurance-based investment products offering a range of options for investments, the insurance undertaking is responsible for designing the product, including selecting the investment options that are offered within the product and for complying with the provisions in Chapter II of the PRIIPs Delegated Regulation. Article 14 sets out the requirements for the specific information document – in particular, please also see the answer to the previous Q&A 4 in this Section. In this context, there is not a requirement for the RHP of the product to be fully aligned with the RHP of individual investment options offered. However, the implications of any differences in RHPs need to be appropriately addressed by the PRIIP manufacturer. This would include, for example, providing the necessary explanations in the KID, as well as more generally ensuring that the product (including investment options) is compatible with the needs, characteristics and objectives of the customers belonging to the target market.