According to the PRIIPs Delegated Regulation, if the MRM class changes to a different MRM class, the PRIIP manufacturer shall attribute the corresponding MRM class to the MRM class which the PRIIP has

First, it should be noted that, in accordance with Article 15 of the PRIIPs Delegated Regulation, the obligation to review the KID applies at least every 12 months, following the date of the initial publication, and needs to be accompanied by an adequate process to monitor the need for revisions to the KID on an ongoing basis. Consequently, even though a PRIIP manufacturer might have recently reviewed and published a revised KID (i.e. less than a year ago), if they identify a need to change the SRI, they have to publish a further revision of the KID. This ongoing monitoring process is intended to ensure that the KID contains fair and not misleading information at all times. Secondly, in accordance with point 53 of Annex II of the PRIIPs Delegated Regulation, the MRM class shall reflect the majority of the reference points over the preceding four months. If a different MRM class is obtained for less than the majority of the reference points over the preceding four months, then the MRM class remains unchanged. A change would only be triggered where the different MRM class is obtained for the majority of reference points. Point 53 intends to provide a smoothing effect such that frequent fluctuations of the MRM class between two neighbouring MRM classes should generally be disregarded. Equally, points 52a and 55 of Annex II of the PRIIPs Delegated Regulation are relevant in this context. A review of the MRM class shall always be carried out following a change in the investment policy or strategy (point 55). Additionally, the PRIIP manufacturer may increase the SRI number if they consider the risk indicator does not adequately reflect the risks of the PRIIP (point 52a); in this case, the decision- making process for such an increase needs to be documented.