ESA Joint Committee · priips-24 Final

The main difference between Category 2 and Category 3 is whether the condition of “constant multiple” is fulfilled in Annex II, Part 1, Point 5. Would it be correct to treat unit-linked insurance prod

Regulation
PRIIPs
Answered
2017-07-04
Answer provided by
ESAs (EBA, ESMA, EIOPA)
⚠

Joint Committee Q&As are published in consolidated PDF documents without explicit question/answer delimiters. Section boundaries below are identified automatically and may occasionally be imprecise.

Question

The main difference between Category 2 and Category 3 is whether the condition of “constant multiple” is fulfilled in Annex II, Part 1, Point 5. Would it be correct to treat unit-linked insurance products with minimal fees charged by the insurer (or absolute fees or fees depending on value) as not fulfilling the definition of “constant multiple” and therefore belonging to Category 3?

Answer

The categorisation referred to in Annex II concerns the MRM of the product. Annex VI and VII concern the calculation and presentation of costs or fees. For insurance-based investment PRIIPs which do not fall into Category 4, the categorisation depends only on the characteristics of the payoff of the PRIIP and the availability of data. It does not depend on the nature of the charges.

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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