Do FX forwards fall within the scope of the PRIIPs Regulation?

Yes. Article 4(1) of the PRIIP Regulation defines PRIP as an investment, where, regardless of the legal form of the investment, the amount repayable to the retail investor is subject to fluctuations because of exposure to reference values or to the performance of one or more assets which are not directly purchased by the retail investor. Under Article 4(3), PRIIPs are defined as a product that is a PRIP and/or an insurance-based investment product. FX forwards are financial instruments under point 4 of Annex C to Directive 2014/65/EU. Their value, and consequently the amount repayable to investors, fluctuates during the holding period in response to changes in relevant interest rates and FX rates. As a result, they should be considered as PRIPs within the meaning of Article 4(1) and as PRIIPs within the meaning of Article 4(3) of the PRIIPs Regulation.