On 15 December 2020 Consob published two resolutions concerning a new procedure for accessing documents containing key information, the so-called KID of the PRIIPs - pre-assembled retail and insurance based investment products marketed in Italy - and information and structured data related to those products (Resolutions no. 21639 and n. 21640 of 15 December 2020).
At the same time, the Operating Instructions which identify the procedure for accessing to the KIDs and the related structured data by Consob have been adopted.
The aforementioned resolutions provide for a transitional period until 31 December 2021.
Communication to Consob in 2021
Until 31 December 2021 only the KID (PDF format) has to be made available to Consob.
To this aim, the following alternative methods are provided:a) It is possible to make the KID accessible within Consob's SFTP server (according to the new Operating Instructions on accessing PRIIPs KIDs and related information, paragraph 5);
b) It is possible to make the KID accessible to Consob using the procedure for the pre-notification to Consob by PEC (certified e-mail) of the KIDs in accordance with the regime in force under previous operating instructions (istruzioni operative per la notifica del KID dei PRIIPs).
In any moment the manufacturer can dismiss the notification by PEC and can switch to the communication by SFTP server (following what is envisaged in the new Operating instructions).
If the manufacturer chooses to make KIDs accessible on Consob's SFTP server, he shall communicate within useful times scheduled in the aforementioned Operating instructions, personal data of PRIIP's manufacturer and all other information concerning the obligations of making KIDs available and provide the configuration activities necessary for communication.
It is permitted to delegate to third parties the fulfilment of the obligations in question, if carried out via SFTP server, thus also making use of external data providers.
Communication to Consob in 2022
Starting from January 1, 2022 PRIIPs manufacturers will be required to make available to Consob both the KIDs (in PDF format) and the related structured data (in XML format) in their personal area within Consob's SFTP server before the start of marketing and in case of any updates- Alternatively, it will be possible to use a web application to make both KIDs and structured data available. Notifications to Consob via PEC (or via email) will not be permitted any longer.
For any technical problems, it is possible to contact the helpdesk number +39 06 8466388 available on working days, from 9.30 a.m. to 5.30 p.m.