ESA Joint Committee · priips-144 Final

Point 52(h) of Annex VI indicates that transaction costs are included in the ‘other ongoing costs’. What does this mean in terms of where transaction costs should be included in table 2 ‘Composition o

Regulation
PRIIPs
Answered
2022-11-14
Answer provided by
ESAs (EBA, ESMA, EIOPA)
⚠

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Question

Point 52(h) of Annex VI indicates that transaction costs are included in the ‘other ongoing costs’. What does this mean in terms of where transaction costs should be included in table 2 ‘Composition of costs” of the Annex VII? As indicated in Point 66 of the Annex VI and in the table 2 of the Annex VII itself, transaction costs should be shown separately in the section “ongoing costs” of the table 2 of the Annex VII. (Answer provided by the ESAs on the application of the PRIIPs Delegated Regulation, revised on 21 December 2022) E. Calculation of the summary cost indicators (Annex VI, Part 2) [Last update 05 May 2025] 1. The Reduction in Yield (RIY) summary cost indicator may be based on the moderate scenario of the performance scenario section of the KID (according to Point 71 (b) of Annex VI), which is based on prices which are already net of charges. Is it therefore necessary to add the charges back into the returns and then deducting all costs to arrive at a net return when calculating the RIY indicator? No, in this case, the estimation of the future benefits for the purpose of the calculation of the RIY indicator shall be calculated according to the methodology and hypothesis used for the calculation of the moderate scenario of the performance scenario section of the KID , without further deductions or calculations. (Answer provided by the ESAs on the application of the PRIIPs Delegated Regulation, revised on 21 December 2022) 2. For a product with tiered charging, is it possible to make an assumption on investment growth to reflect in the cost over time section given it is difficult to determine what the underlying assets are? The assumptions to use are specified in Point 71 of Annex VI. Where point 71(a) does not apply, the estimation of the future benefits for the purpose of the calculation of the RIY indicator shall be calculated according to the methodology and hypothesis used for the estimation of the moderate scenario of the performance scenario section of the KID. (Answer provided by the ESAs on the application of the PRIIPs Delegated Regulation, revised on 21 December 2022) 3. In the case of unit-linked products the underlying of which are UCITS, is it possible to use a predetermined yield for the purpose of the estimation of the benefits to be used in the calculation of the RIY indicator? The assumptions to use are specified in Point 71 of Annex VI. Where point 71(a) does not apply, the estimation of the future benefits for the purpose of the calculation of the RIY indicator shall be calculated according to the methodology and hypothesis used for the estimation of the moderate scenario of the performance scenario section of the KID. Please also refer to Points 74 to 76 of Annex VI which are specific to insurance-based investment products. (Answer provided by the ESAs on the application of the PRIIPs Delegated Regulation, revised on 21 December 2022) 4. If the moderate scenario shows a total loss of capital or even a negative return, should this be used to present the costs, in which case the Reduction-in-Yield would suggest no or very low costs?

Answer

Where the moderate scenario shows the total loss of capital invested or more (i.e. is less than or zero), point 71(a) of Annex VI should be applied in order to avoid potential errors in the calculation. That is a net performance of 0% is assumed for the purposes of determining the reduction in yield. (Answer provided by the ESAs on the application of the PRIIPs Delegated Regulation, revised on 21 December 2022) 5. Costs of the PRIIP after 1 year, first table on costs, Annex VII of the Delegated Regulation - performance after 1 year is to be calculated with net performance of 0%. For products with ongoing premiums this requires an artificially very high assumed gross performance due to one-off costs. Furthermore, the mandatory explanation sentence “In the first year you would get back the amount that you invested (0 % annual return).” could be misleading for consumers In accordance with point 71 of Annex VI of the Delegated Regulation an assumption of 0% net performance applies for all PRIIPs for the cost indicators showing the case that the PRIIP is held for one year or less.

This Q&A is published by ESA Joint Committee (EBA, ESMA, EIOPA) and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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