Does the requirements in Articles 6(1) and 9 of the PRIIPs Regulation mean that past performance disclosed regarding a benchmark index should be consistent with past performance disclosure in other in

Yes. PRIIP manufacturers should ensure that disclosure of past performance is not misleading by way of being inconsistent, including by ensuring consistency: • Across legal and regulatory documents (including the prospectus) and marketing communications. It may be unclear to investors if the PRIIP names and measures performance against a benchmark index mentioned e.g. in the prospectus, or in marketing communications, but not in the disclosure of past performance in accordance with Annex VIII of the PRIIPs Delegated Regulation. The disclosure of past performance should be consistent with other product documents. This also applies to ensuring that the benchmark index used is consistent. • Across distribution channels. It may be inconsistent if a PRIIP arranges for, or permits, an index to be referred to as a benchmark in certain media, such as online platforms or financial data providers, but it does not make the same comparison in the disclosure of past performance in accordance with Annex VIII. This also applies to ensuring that the benchmark index used is consistent. • Across investor types. It should be ensured that all types of investors receive consistent and not misleading information regarding whether or not the PRIIP has a benchmark index. For example, it may be inconsistent if a PRIIP suggests performance should be measured against a benchmark index to only a cohort of investors (such as in communications to professional investors only) but does not provide the equivalent performance comparison to all investors through the disclosure of past performance in accordance with Annex VIII. This also applies to ensuring the version of the benchmark index used is consistent.