It is commonly known that the UCITS KIIDs need to be updated every year within the first 35 business years of every new year. Last year the PRIIPs KID replaced the UCITS KIID, but same as before, also the PRIIPs KID needs an annual update according to the regulation. There was still uncertainty about the exact date when the PRIIPs KID needs to be updated. To clarify this question, the CSSF updated their FAQs on 29th December 2023:
“Does a specific yearly timeline apply in connection with the annual update of PRIIPs KID for Luxembourg UCITS?
No. Article 15 of Commission Delegated Regulation (EU) 2017/653 requires PRIIP manufacturers to review the information contained in the PRIIPs KID at least every 12 months following the date of the initial publication of the PRIIPs KID without providing for a specific yearly timeline for such annual update.
However, PRIIPs manufacturers are encouraged to annually update the PRIIPs KID for UCITS and to subsequently submit such document to the CSSF within 35 business days after 31 December of each year.”
As for most of the funds, the first PRIIPs KIDs were published in January 2022, those 35 business days which brings us to the 19th February 2024 are the actual deadline.
While the EU switched to PRIIPs KIDs for funds, the UK remains with UCITS KIIDs at least for the next 4 years. Concerning the annual update for UCITS KIIDs in the UK, the timeline of the 35 business days hasn’t changed.
Sources: CSSF, FCA
