According to Point 21 of the Annex VI of the Commission Delegated Regulation for PRIIPs that have been operating less than 3 years transaction costs may be calculated as an average of the actual trans

According to Point 21 of the Annex VI of the Commission Delegated Regulation for PRIIPs that have been operating less than 3 years transaction costs may be calculated as an average of the actual transaction costs incurred during the period of operation and a standardised estimate. When and how should the costs be calculated? Using the example of a new product and where the KID is revised annually: At the occasion of the first annual review the product manufacturer can use data about the actual transaction costs for the first six months of the PRIIPs existence and for the remaining 30 months (to give an average over 3 years), would use the estimate of portfolio turnover in each asset class according to the methodology referred to in Point 21(c). Accordingly, at the second annual review the product manufacturer may use 18 months of actual data and for the remaining 18 months the standardised estimate. (Answer provided by the ESAs on the application of the PRIIPs Delegated Regulation, revised on 21 December 2022) 3. Transaction costs are based on the average of the previous three years, but some managers have not been collecting these in the detail required (with the "arrival price") by Annex VI. How to calculate transaction costs in this case?