On 15 December 2020, new methods of access to documents containing key information, the so-called KIDs of PRIIPs - pre-assembled retail and insurance investment products - were defined and the obligation to make information and structured data relating to PRIIPs marketed in Italy accessible to Consob was established (Resolutions no. 21639 and no. 21640 of 15 December 2020).
The aforementioned resolutions provided for a transitional period on the basis of which:
a) the obligation to make the KID available in PDF format via Consob's SFTP server entered into force on 1 January 2021, although the creators of PRIIPs were granted the possibility of making use, until 31 December 2021, of the regime in force, consisting in the prior notification of the KIDs to Consob via certified mail (PEC);
b) the obligation to make the information and structured data relating to the PRIIPs accessible to Consob is fulfilled by making it available on an SFTP server or via a web interface and applies from 1 January 2022.
With Resolution no. 22134 of 17 December 2021 the possibility of making the KID accessible to Consob via PEC was extended until 28 February 2022, while the commencement of the obligations envisaged by the aforementioned resolution 21640 was postponed to 1 March 2022, to grant further adjustment time with relation to specific requests in this regard.
The methods for fulfilling the aforementioned obligations are specified in the specific operating instructions published on Consob's website https://www.consob.it/web/area-operativa-interattiva/priips.
For the purpose of meeting the requirements set out in Resolution 21640 of 15 December 2020, the "technical specifications containing the XSD schemes "necessary to fulfil the obligation to make structured data accessible on Consob's SFTP servers were also published on Consob's website https://www.consob.it/web/area-operativa-interattiva/priips.
Finally, the guidebook relating to the use of the web interface will be made available on 20 December 2021, in the same section of the site.
With regard to CIS already subject to the PRIIPs Regulation, the acquisition of the KID and the related structured data can be carried out, alternatively to making it available through the KID PRIIPs System (so-called SIKID PRIIPs), by the way of the DEPROF System, whose guidebook was updated to reflect this alternative method of acquisition. Managers who intend to make use of the DEPROF, for the purposes of the aforementioned obligations, will be able to access it through the credentials already assigned by Consob when starting operations in Italy.
It is therefore recalled that the transitional period ends on 28 February 2022; from 1 March 2022, the provisions relating to the acquisition of KIDs and related structured data will apply in the manner indicated above and detailed in the specific instructions available on Consob's website.