Where a UCITS, AIF or unit-linked insurance-based investment product refers to an index in its investment objectives and policy as a benchmark and will measure the performance against that index, but

Yes, in accordance with point 11 of Annex VIII of the Delegated Regulation, a bar showing the performance of the benchmark index must be included in the bar chart alongside each bar showing the past performance of the PRIIP. It should be made clear that the performance is not tracking the index. For additional clarity, point 11 of Annex VIII applies to all UCITS, AIFs and unit-linked insurance-based investment products, including total return/absolute return UCITS. For example, the requirement also applies to cases where: • The comparator is not named a ‘benchmark’, but the PRIIP’s objectives and investment policy make it clear that it is a comparator the UCITS, AIF or unit-linked insurance-based investment product aims to outperform. For example, if the fund’s objectives and investment policy state it will seek to: o outperform cash (for example, 3-month EURIBOR), the performance of the PRIIP against the full target should be shown o outperform a target ‘plus X%’, the performance of the PRIIP against the enhanced target should be shown. • The UCITS, AIF or unit-linked insurance-based investment product targets outperformance of the benchmark index over a period of time, for example ‘X% per annum over four years’. In this case, annualised past performance of the benchmark index should be shown alongside that of the UCITS, or AIF or unit-linked insurance-based investment product, even if the target is to beat it over four years. To ensure fair, clear and not misleading communications, the information disclosed in the UCITS or AIF KID should be consistent with the UCITS’ or AIF Investment Objective in the legal and regulatory fund documents, such as the Prospectus or the offering memorandum.