Retail Investment Strategy · PRIIPs

The 2028 KID rewrite: what the Retail Investment Strategy changes, and when

Article references checked against COM(2023) 278 on EUR-Lex; status against the EP Legislative Observatory · last updated 21 September 2026

The Retail Investment Strategy (RIS) is the largest change to the PRIIPs Key Information Document since the regime began. After three years of negotiation, the final compromise text is agreed. Every manufacturer of funds, ETFs, structured products and insurance-based investment products in the EU will have to produce every KID again, on a new template.

What changes in the KID

Article references are to the Commission proposal, COM(2023) 278, which amends Regulation (EU) No 1286/2014. Points below are the ones stated in that text.

A mandatory "product at a glance" dashboard. Five values in one block at the top of the document: product type, the summary risk indicator, total costs, the recommended holding period, and whether the product offers insurance benefits (Article 8(3)(aa)). Nothing new is being asked for. All five must already be in the document today.
A new section, "How environmentally sustainable is this product?" The minimum proportion of investment aligned with the Taxonomy Regulation, and the expected greenhouse gas emissions intensity (Article 8(3)(ga)). This is the only part of the proposal that brings in information from outside today's KID: it is drawn from the SFDR pre-contractual disclosures.
The comprehension alert goes. Article 8(3)(b) is deleted; the Commission's stated reason is that it "has not been sufficiently effective".
Electronic by default, and layered if you want. Paper on request, free of charge. Where a layered format is used, the dashboard must appear in the first layer, and manufacturers must supply previous versions of a KID on request (Article 14).
Revision rules will distinguish products still being marketed from products that are not. The ESAs are to write that distinction into the technical standards (Article 10(2)(b)). This is the back-book problem being written into the rules.
The three-page limit stays. The proposal touches only Article 6(3) of the Regulation, which concerns multi-option products. Article 6(4), the limit of three sides of A4, is untouched.

One point often reported about RIS is not in this text: performance scenarios are not replaced by past performance. The four scenarios required by Article 3(3) of Delegated Regulation 2017/653, and the fifth for insurance-based products under Article 3(4), are not amended by the proposal, and the phrase "past performance" does not appear in it. Past performance for UCITS, AIFs and unit-linked products is already required today, under Article 8(3) of that Delegated Regulation as amended in 2021. Should the agreed text change this, we will say so here.

The timeline

18 Dec 2025Political agreement between Parliament and Council.

Jun 2026Final compromise text endorsed; approved in ECON committee.

11 Nov 2026European Parliament plenary vote (first reading), the next formal step. The procedure file gives this as an indicative sitting date, so it can move; the substance was settled in June.

~2027Publication in the Official Journal; entry into force.

~2028New PRIIPs rules apply, 18 months after publication. Every KID re-produced.

from 2028PRIIPs KIDs are filed to the European Single Access Point with a legal entity identifier. The proposal notes this "could make such information machine readable", depending on the implementing acts adopted.

Dates beyond November 2026 are estimates derived from the 18-month application period set in the proposal; they shift with the Official Journal publication date.

Status as at 23 September 2026, re-checked against both procedure files on that date. The authoritative record is the European Parliament's procedure file 2023/0166(COD), which amends the PRIIPs Regulation and updates as the file moves; the accompanying omnibus directive is 2023/0167(COD). Where this page and the procedure file disagree, the procedure file is right.

What the migration will actually test

The last template change took effect on 1 January 2023. Almost four years later, we still find documents on the abolished template in live circulation. At one major European issuer, 18.5% of sampled products are served on the pre-2023 format, the oldest produced in 2020 and now past six years without review. Not because anyone lacked the skill to rewrite them. Because nobody could say exactly how many files were on the shelf and which one was current.

The 2028 migration is not a document-writing project. It is a data-governance test: do you know what you have published, where, in which languages, and in which versions? That test can be passed before the exam.

What manufacturers can do now

Inventory the estate. Every live KID, every language, every distribution channel that hosts a copy. Most firms discover documents they did not know were still being served.
Baseline the estate against the current rules. A shelf that cannot stay conformant with a stable template will not survive a re-templating. Fix the governance gap first; the 2028 rewrite then becomes mechanical.
Prepare for machine-readability. If your documents and your data feeds (EPT) already disagree today, machine-readable disclosure will expose it instantly.

Know where your shelf stands before the migration

We audit published KIDs against Delegated Regulation (EU) 2017/653: 2,950+ live documents checked so far, across 40+ manufacturers in 7 languages. Free pilot: five documents drawn from across your range, full findings in 48 hours.

Request the free check

or write to hello@kidcheck.eu · methodology: the full report

This page summarises the agreed RIS compromise text as it stands; it is not legal advice. Facts verified at source: EP Legislative Observatory (procedure 2023/0166(COD)) and EUR-Lex.