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Retail Investment Strategy (RIS)

Impacts and implementation timeline

The new Retail Investment Strategy (RIS) package will usher in significant sweeping changes across the banking, insurance, and investment management sectors.

RIS proposes significant changes to the Packaged Retail and Insurance-Based Investment Products (PRIIPs) Regulation and includes an Omnibus Directive that will amend the following directives:

  • Markets in Financial Instruments Directive (MiFID) II
  • Insurance Distribution Directive (IDD)
  • Undertakings for Collective Investment in Transferrable Securities (UCITS) V Directive
  • Alternative Investment Fund Managers Directive (AIFMD)


These regulatory changes aim to ensure retail investors can access better investment options and receive fair treatment and value for money in the market.

A closer look

In May 2023, the European Commission launched discussions on the new Retail Investment Strategy (RIS) as a way to offer retail investors safer investment opportunities and address other prevalent issues within the investment industry.

This latest version of the RIS Package was released by ECON parliament committee and then endorsed by European Parliament on 23 April 2024. The package amends several regulations; you can find the anticipated impacts detailed below.

Banking

  • New consumer protection tools
  • Improved suitability with risk, diversification and cost considerations
  • Identification and warning of risky and complex investment products
  • Transmission of product data by manufacturers and distributors to national competent authorities (NCA)
  • Creation of new product benchmarks by the European Insurance and Occupational Pensions Authority (EIOPA) and European Securities and Markets Authority (ESMA)
  • New minimum knowledge and competence standards required for financial advisors
  • Rules on information sharing when providing cross-border services
  • Updates on client reporting to coordinate the disclosures
  • New obligations around social media promotion through financial influencers, or "finfluencers"
  • Requirement to archive marketing communication made within the duration of the client relationship
  • Introduction of insurance product information document (IPID) for life insurance products

After Council’s approval:

  • Removal of the proposed ban on inducements for execution-only sales
  • Strengthened safeguards for inducements, including an inducement test and a uniform test specifying the duty for advisors to act in the client's best interest
  • Enhanced transparency about what payments are considered inducements, their costs, and their impact on investment returns
  • Overarching principles to prevent conflicts of interest in the case of inducements
  • Option for Member States to use Union supervisory benchmarks for market comparisons
  • Requirement for manufacturers and distributors to compare their products to a peer group of similar investment products within the EU
  • Review of the Value for Money framework seven years after implementation
  • New "Product at a glance" section at beginning of the key information document (KID)
  • Removal of comprehension alert
  • Dedicated section on sustainability aligned with the Sustainable Finance Disclosure Regulation (SFDR)
  • More flexibility to include past performance along with performance scenarios in the KID
  • Prioritization of multi-option products (MOPs) with the requirement to develop a tool to compare different investment options

After Council’s approval:

  • Enhanced digital access to KIDs to help investors better understand and compare investment products
  • Additional product approval requirements for manufacturers
  • Peer-group requirements when manufacturing or distributing a PRIIP
  • Ban on inducement for portfolio management
  • New €100 threshold for independence impairment
  • Additional requirements for investment advice to retail investor

After Council approval:

  • Standardization of investor protection rules across different sectors and EU laws
  • Measures to ensure fair value and prevent conflicts of interest due to inducements
  • Increased transparency requirements for costs, charges, and performance

Investment Management

  • New consumer protection tools
  • Improved suitability with risk, diversification and cost considerations
  • Identification and warning of risky and complex investment products
  • Transmission of product data by manufacturers and distributors to national competent authorities (NCA)
  • Creation of new product benchmarks by the European Insurance and Occupational Pensions Authority (EIOPA) and European Securities and Markets Authority (ESMA)
  • New minimum knowledge and competence standards required for financial advisors
  • Rules on information sharing when providing cross-border services
  • Updates on client reporting to coordinate the disclosures
  • New obligations around social media promotion through financial influencers, or "finfluencers"
  • Requirement to archive marketing communication made within the duration of the client relationship
  • Introduction of insurance product information document (IPID) for life insurance products

After Council’s approval:

  • Removal of the proposed ban on inducements for execution-only sales
  • Strengthened safeguards for inducements, including an inducement test and a uniform test specifying the duty for advisors to act in the client's best interest
  • Enhanced transparency about what payments are considered inducements, their costs, and their impact on investment returns
  • Overarching principles to prevent conflicts of interest in the case of inducements
  • Option for Member States to use Union supervisory benchmarks for market comparisons
  • Requirement for manufacturers and distributors to compare their products to a peer group of similar investment products within the EU
  • Review of the Value for Money framework seven years after implementation
  • New "Product at a glance" section at beginning of the key information document (KID)
  • Removal of comprehension alert
  • Dedicated section on sustainability aligned with the Sustainable Finance Disclosure Regulation (SFDR)
  • More flexibility to include past performance along with performance scenarios in the KID
  • Prioritization of multi-option products (MOPs) with the requirement to develop a tool to compare different investment options

After Council’s approval:

  • Enhanced digital access to KIDs to help investors better understand and compare investment products
  • Additional product approval requirements for manufacturers
  • Peer-group requirements when manufacturing or distributing a PRIIP
  • Ban on inducement for portfolio management
  • New €100 threshold for independence impairment
  • Additional requirements for investment advice to retail investor

After Council approval:

  • Standardization of investor protection rules across different sectors and EU laws
  • Measures to ensure fair value and prevent conflicts of interest due to inducements
  • Increased transparency requirements for costs, charges, and performance
  • Clarification of "undue costs" classification and required documentation
  • Management fees to monitor pricing process and ensure appropriateness of the costs to the value delivered
  • Investor compensation mechanisms
  • Market comparisons to be considered in pricing process
  • New reporting of costs and performance to the national competent authority (NCA)

After Council approval:

  • Standardization of transparency and disclosure requirements to avoid overlaps
  • Improved regulatory disclosures to help investors better understand and compare UCITS products
  • Clarification of "undue costs" classification and required documentation
  • Management fees to monitor pricing process and ensure appropriateness of the costs to the value delivered
  • Investor compensation mechanisms
  • Market comparisons to be considered in pricing process
  • New reporting of costs and performance to the national competent authority (NCA)

After Council approval:

  • Alignment of transparency and information requirements with other EU legislation
  • Enhanced supervisory cooperation to ensure consistent application of rules across the EU

Insurance

  • New consumer protection tools
  • Improved suitability with risk, diversification and cost considerations
  • Identification and warning of risky and complex investment products
  • Transmission of product data by manufacturers and distributors to national competent authorities (NCA)
  • Creation of new product benchmarks by the European Insurance and Occupational Pensions Authority (EIOPA) and European Securities and Markets Authority (ESMA)
  • New minimum knowledge and competence standards required for financial advisors
  • Rules on information sharing when providing cross-border services
  • Updates on client reporting to coordinate the disclosures
  • New obligations around social media promotion through financial influencers, or "finfluencers"
  • Requirement to archive marketing communication made within the duration of the client relationship
  • Introduction of insurance product information document (IPID) for life insurance products

After Council’s approval:

  • Removal of the proposed ban on inducements for execution-only sales
  • Strengthened safeguards for inducements, including an inducement test and a uniform test specifying the duty for advisors to act in the client's best interest
  • Enhanced transparency about what payments are considered inducements, their costs, and their impact on investment returns
  • Overarching principles to prevent conflicts of interest in the case of inducements
  • Option for Member States to use Union supervisory benchmarks for market comparisons
  • Requirement for manufacturers and distributors to compare their products to a peer group of similar investment products within the EU
  • Review of the Value for Money framework seven years after implementation
  • New "Product at a glance" section at beginning of the key information document (KID)
  • Removal of comprehension alert
  • Dedicated section on sustainability aligned with the Sustainable Finance Disclosure Regulation (SFDR)
  • More flexibility to include past performance along with performance scenarios in the KID
  • Prioritization of multi-option products (MOPs) with the requirement to develop a tool to compare different investment options

After Council’s approval:

  • Enhanced digital access to KIDs to help investors better understand and compare investment products
  • Distributors with cross-border activities to report relevant information for a European database each year in order to enhance supervisory cooperation within EU
  • Improvements and adjustments of required professional qualifications,  particularly for intermediaries providing advice on integration of sustainability preferences into insurance-based investment products.
  • Development of a European benchmark for insurance-based investment products distributed across multiple Member States
  • Additional information in the insurance product’s information document for specific life insurance products
  • Transition from paper to electronic format for information provided to customers
  • Enhancement of product oversight and governance requirements
  • Introduction of an annual statement for retail policyholders and update of the pre-contractual information to include personalized information using a standard format and language
  • Option to impose stricter requirements on insurance intermediaries and undertakings as they relate to inducements,
  • New requirement to inform, assess and recommend the insurance-based investment products and underlying investment options which best suit the customer’s needs  and best interest
  • Improvement of the assessment of suitability and appropriateness of insurance-based investment products
  • Restrictions on online insurance distribution practices

Removal of the requirements regarding information provided to the policyholders.

Next steps

Trialogue has started between European Council, Parliament and Commission to agree on final version of the RIS Package. It is expected that the final text will be released and voted on in the second half of 2025.

How Deloitte can help

Deloitte’s RegWatch helps keep you informed of regulatory updates so that you can anticipate changes that will impact your business and organization.

Deloitte’s Advisory & Consulting services can help you with the following:

  • Assess how RIS will impact your business.
  • Understand the requirements and interpretations of specific amendments.
  • Assess and define a business strategy in light of the RIS objectives.
  • Perform an impact assessment and gap analysis of your organization.
  • Provide guidance with updating your compliance control framework and policies.

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