Procedure of communication of PRIIPS KID - SERVICES FOR SUPERVISED SUBJECTS
Procedure of communication of PRIIPs KID marketed in Italy
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.
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.
A transitional period has been envisaged until 28 February 2022.
Communication to Consob until February 2022
Until 28 February 2022 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 from 1 March 2022
Starting from March 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.
From December 20, 2021 is available the Web interface. Until February 28, 2022 it is possible to enter into the application only as trial hence without the permission to end up the process of making available KID and structured data.
Regarding subjects already owning credential for SFTP without delegation of the current fulfilments to third party it is possible to use the credentials previously released by Consob in order to enter into Web interface.
Regarding subjects already registered with active delegation of the current fulfilments to third party, Consob will release specific credentials to enter into Web interface either automatically within May 2022 or by request of the subject to email@example.com.
Regarding subject not yet registered is available a new version of the "PRIIPs manufacturer" form in order to get the credentials.
To use Web Interface the manufacturer can be supported by a third party, keeping all the responsibilities for the information provided.
In order to support users the manual "Manuale delle istruzioni per l'utilizzo del sistema per la messa a disposizione dei kid e dei dati strutturati di prodotti di investimento al dettaglio e assicurativi preassemblati (PRIIPs)" has been published (provisionally in Italian version only).
For any technical problems, it is possible to contact the helpdesk number
+39 06 8477 388 available on working days, from 9.30 a.m. to 5.30 p.m.