PRIIPs Key Information Document (KID) Template

PRIIP scope test, manufacturer duties, MRM, CRM and SRI, performance scenarios, costs tables, KID draft, review, delivery, reform watch

Finance, Investment & AccountingFullPRIIPs Regulation (EU) 1286/2014; Delegated Regulation (EU) 2017/653 as amended by (EU) 2021/2268priips kid mathUpdated Oct 29, 2026

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How to use: Use it when you manufacture a packaged retail or insurance-based investment product sold to EEA retail investors. Fill the category, SRI, scenario and cost workings in Part A first, then the KID sections in Part B from the same numbers. The main pitfall is cost figures that leave out margins embedded in the issue price.

Preview

Key Information Document (PRIIPs KID): [Product name]

Production file and draft key information document (KID) for a packaged retail and insurance-based investment product (PRIIP) sold to retail investors in the European Economic Area. Based on Regulation (EU) No 1286/2014 (the PRIIPs Regulation, applying since 2018-01-01) and Commission Delegated Regulation (EU) 2017/653 (the PRIIPs RTS) as amended by Delegated Regulation (EU) 2021/2268, whose changes to performance scenarios and cost presentation apply from 2023-01-01. Part A records the methodology behind the numbers: product category, summary risk indicator (SRI), performance scenarios and costs. Part B is the KID itself, in the order and with the section titles the Regulation prescribes. Amendments under the EU Retail Investment Strategy were agreed politically in December 2025 and are not yet applicable; check section 9 and the consolidated texts. Replace every [bracketed] value and every row marked Example. This is a documentation format, not legal, investment or financial advice.

Document control

Field	Value
Document ID	[KID-YYYY-NNN] Example: KID-2026-031
Product name and identifier	[Name, ISIN or other identifier] Example: Kestrel Bay Euro Equity Participation Note 2031, [ISIN]
PRIIP manufacturer named in the KID	[Legal name, website, telephone] Example: Fernhollow Bank
Competent authority of the manufacturer	[Name]
PRIIP category (RTS Annex II)	[1 / 2 / 3 / 4] Example: 3
Recommended holding period (RHP)	[Years] Example: 5 years (to maturity 2031-12-15)
Languages and Member States of distribution	[List]
Linked target market assessment	[ID] Example: TMA-2026-007
Calculation workbook and data date	[Reference, YYYY-MM-DD]
Version	[0.1]
Status	[Draft / In review / Approved / Published / Superseded]
Owner	[@kid-product-owner]
Approvers/reviewers	[@product-governance], [@risk-quant], [@legal], [@compliance]
Last updated	YYYY-MM-DD
Date of production shown in the KID	YYYY-MM-DD
Classification	[Internal for Part A; Public for Part B once published]

Approvals

Role	Name	Decision	Date
Quantitative analyst (SRI, scenarios, costs)	[@name]	[Calculations complete]	YYYY-MM-DD
Independent model validation or second check	[@name]	[Results reproduced]	YYYY-MM-DD
Legal (prescribed text, liability)	[@name]	[Approved]	YYYY-MM-DD
Compliance (consistency with marketing and target market)	[@name]	[Approved]	YYYY-MM-DD
Product approval committee	[@chair]	[Approved for publication]	YYYY-MM-DD

Revision history

Version	Date	Author	Change summary
0.1	YYYY-MM-DD	[@name]	First draft from the term sheet
1.0	YYYY-MM-DD	[@name]	Example: Approved and published before the subscription period
1.1	YYYY-MM-DD	[@name]	Example: Scheduled review after 12 months; scenarios and costs re-run, SRI unchanged

Part A, production file:

Scope and manufacturer duties
Product category and summary risk indicator
Performance scenarios
Costs

Part B, the KID:

Key information document draft

Part A, continued:

Review, revision and publication
Delivery and record keeping
Quality checks and sign-off
Reform watch and jurisdiction notes
Glossary and references
Standard and licence note

1. Scope and manufacturer duties

1.1 Is the product a PRIIP?

Under PRIIPs Regulation Article 4, a packaged retail investment product is an investment where the amount repayable to the retail investor fluctuates because of exposure to reference values or to the performance of assets not directly purchased by the investor; an insurance-based investment product is an insurance product whose maturity or surrender value is exposed to market fluctuations. Article 2(2) excludes, among others, non-life insurance, life insurance contracts paying benefits only on death or incapacity, deposits other than structured deposits, certain securities, and recognised pension products. Record the analysis.

Question	Answer (Example)	Evidence
Does the repayable amount depend on a reference value or on assets not directly held?	Yes, on a European large-cap equity index	Term sheet, payoff formula
Does an Article 2(2) exclusion apply?	No	Legal review LR-2026-118
Is it made available to retail investors in the EEA?	Yes, in [Member States]	Distribution plan
Result	KID required

1.2 Manufacturer obligations checklist

Duty	Basis	Owner	Status
Draw up the KID before the product is made available to retail investors and publish it on the manufacturer's website	PRIIPs Reg. Art. 5(1)	[@kid-product-owner]	[Done / Open]
Keep the KID accurate, fair, clear and not misleading, consistent with binding contractual documents and offer documents	Art. 6(1)	[@legal]	[Done / Open]
Stand-alone document, at most three sides of A4 printed, clearly separate from marketing material	Art. 6(2) to (4)	[@legal]	[Done / Open]
Content and order of sections as prescribed	Art. 8 and RTS Art. 1 to 13 with annexes	[@kid-product-owner]	[Done / Open]
Language: official language or one accepted by the Member State of distribution	Art. 7	[@product-governance]	[Done / Open]
Review the information regularly and revise where necessary	Art. 10 and RTS Art. 15 and 16	[@kid-product-owner]	[Done / Open]
Notify the KID to the competent authority where a Member State requires it	Art. 5(2)	[@compliance]	[Done / Not required]
Establish complaint procedures for the KID	Art. 19	[@complaints]	[Done / Open]

Civil liability: under Article 11, an investor who relied on a misleading, inaccurate or inconsistent KID may claim damages from the manufacturer under national law. This is a reason to keep the evidence file in Parts A and 8 complete.

2. Product category and summary risk indicator

2.1 Category

RTS Annex II, Part 1 sorts PRIIPs into four categories for the market risk assessment. In short: category 1 covers products where the investor can lose more than the amount invested, leveraged products and products priced less often than monthly (among others); category 2 covers products with a linear exposure to their underlying; category 3 covers products with a non-linear exposure (for example capital floors, caps or barriers); category 4 covers products whose value depends on factors not observable in the market, such as profit participation in insurance products. Read the RTS text for the full criteria.

Example: The note pays 70% of the index rise with a 90% floor at maturity, a non-linear payoff, so it is a category 3 PRIIP.

2.2 Market risk measure

For category 2 and 3 products the MRM class follows from the VaR-equivalent volatility (VEV) over the RHP at a 97.5% confidence level. The RTS bands are: class 1 below 0.5%, class 2 from 0.5% to 5%, class 3 from 5% to 12%, class 4 from 12% to 20%, class 5 from 20% to 30%, class 6 from 30% to 80% and class 7 above 80%. Product history of at least five years of daily prices (or a benchmark or proxy as the RTS allows) is expected for the calculation.

For category 3 products the VEV is derived from the simulated return at the 2.5th percentile at the RHP (the VaR in return space, VaR<sub>RP</sub>) and the RHP in years T:

\text{VEV} = \frac{\sqrt{3.842 - 2\ln(\text{VaR}_{RP})} - 1.96}{\sqrt{T}}

Example: in the simulation that ignores issuer default (as the market risk step requires), the 2.5th percentile outcome at maturity is the 90% floor, so VaR<sub>RP</sub> = 0.90 and T = 5. Then 2 x ln(0.90) = -0.2107, the square root of 3.842 + 0.2107 = 4.0527 is 2.0131, minus 1.96 gives 0.0531, and divided by the square root of 5 (2.2361) the VEV is 2.38%. That falls in the band from 0.5% to 5%, so the MRM class is 2. Confirm the formula and the treatment of the floor against the current RTS Annex II text.

2.3 Credit risk measure

The CRM (1 to 6) depends on the credit quality of the party that must pay (the issuer or guarantor), its credit quality step, an adjustment for the maturity of the product and mitigating factors such as collateral (RTS Annex II, Part 2). The CRM can only raise the SRI above the MRM, never lower it (ESA Q&A on the SRI).

Example: the note is unsecured senior preferred debt of Fernhollow Bank and the issuer's assessment maps to a credit quality step that, after the maturity adjustment for a five-year product, gives CRM class 3.

2.4 Summary risk indicator

Input	Result (Example)	Source
Category	3	Section 2.1
VEV	2.38%	Section 2.2
MRM class	2	Section 2.2
CRM class	3	Section 2.3
SRI from the combination table (RTS Annex II, Part 3)	3	Workbook tab SRI
Liquidity adjustment or narrative	Narrative: early exit price may be well below the floor	Section 5.4

Example: the combination of MRM 2 and CRM 3 gives SRI 3 on the 1 to 7 scale, the class quoted in TMA-2026-007. Read the class from the current combination table in the RTS; do not derive it by rule of thumb.

3. Performance scenarios

3.1 Method

Delegated Regulation (EU) 2021/2268 replaced the earlier scenario method from 2023-01-01. For category 2 products, the unfavourable, moderate and favourable scenarios are taken from the product's (or a benchmark's) historical returns over a look-back period; for category 3 products they come from a simulation of the payoff; the stress scenario uses a separate stressed volatility method under RTS Article 3(3) and Annex IV. Figures are shown net of all costs in Section 4, in the currency of the product, for the illustrative investment set by the RTS (for most PRIIPs EUR 10,000; Annex VI, point 90, as referred to in the ESA Q&A).

3.2 Worked scenarios

Payoff at maturity per EUR 10,000 invested: 10,000 x max(0.90, 1 + 0.70 x r), where r is the index return from the strike date to the final valuation date. Values after one year are early exit values from the secondary market bid, which is not protected by the floor.

Scenario	Index return to maturity (Example)	Value if you exit after 1 year (Example)	Average return after 1 year	Value at the RHP of 5 years	Average return each year
Stress	-45%	7,120	-28.8%	9,000	-2.09%
Unfavourable	-20%	8,850	-11.5%	9,000	-2.09%
Moderate	+18%	9,880	-1.2%	11,260	2.40%
Favourable	+45%	10,950	+9.5%	13,150	5.63%

Recompute the maturity values: stress 1 + 0.70 x (-0.45) = 0.685, below the floor, so 9,000; unfavourable 1 + 0.70 x (-0.20) = 0.86, below the floor, so 9,000; moderate 1 + 0.70 x 0.18 = 1.126, so 11,260; favourable 1 + 0.70 x 0.45 = 1.315, so 13,150. Average annual returns are (value / 10,000) to the power 1/5, minus 1: 0.90 gives -2.09%, 1.126 gives 2.40%, 1.315 gives 5.63%. One-year returns are value / 10,000 minus 1. The one-year values are illustrative inputs, not computed here; in a real KID they come from the RTS simulation.

The index moves in the table are illustrations chosen to show the payoff, not the RTS percentiles. In a real KID, each scenario value is the percentile outcome the RTS specifies, and the narrative explains that the floor applies only at maturity and only if Fernhollow Bank pays.

4. Costs

4.1 Cost inventory

Cost type (RTS Annex VI)	Description (Example)	Amount on EUR 10,000	Treatment
One-off entry costs	Structuring and hedging margin of the issuer 2.40% and distribution fee 0.60%, both embedded in the issue price	300	Entry cost
One-off exit costs	None at maturity; before maturity the issuer's bid is about 1% below fair value	0 at maturity, about 1% of value on early exit	Exit cost for the one-year column
Ongoing costs: management and other administrative or operating costs	None	0
Ongoing costs: portfolio transaction costs	None	0
Incidental costs: performance fees, carried interest	None	0

These amounts agree with the cost section of TMA-2026-007 (structuring and hedging 2.40%, distribution 0.60%, total 3.00% over the term).

4.2 Costs over time

The first table shows the total costs in EUR and their annual impact for exit after one year and at the RHP. The RTS assumptions are a 0% annual return in the first year and the moderate scenario for other holding periods, on EUR 10,000 invested.

Investment EUR 10,000 (Example)	If you exit after 1 year	If you exit after 5 years (RHP)
Total costs	EUR 397	EUR 348
Annual cost impact (*)	4.0%	0.6% each year

(*) This shows how costs reduce the return each year over the holding period. Example: if you exit at the RHP, the average annual return is projected to be 3.0% before costs and 2.4% after costs.

Recompute the one-year column: the issue price buys a fair value of 9,700 (10,000 minus 300 of embedded entry costs); with a 0% return the early exit bid is 1% below that fair value, so 9,700 x 0.99 = 9,603, total costs 10,000 minus 9,603 = 397, which is 3.97% and is shown as 4.0%. Recompute the RHP column: the moderate net value is 11,260; the gross growth on the fair value is 11,260 / 9,700 = 1.16082, so the gross value on 10,000 would be 11,608; total costs 11,608 minus 11,260 = 348. Gross annual return 1.16082 to the power 1/5, minus 1 = 3.03%; net annual return 1.126 to the power 1/5, minus 1 = 2.40%; the difference is 0.63% a year, shown as 0.6%.

4.3 Composition of costs

The second table splits the annual cost impact at the RHP by cost type.

One-off costs upon entry or exit (Example)	Description	Annual cost impact if you exit after 5 years
Entry costs	3.00% of the amount you pay, embedded in the price; includes a distribution fee of 0.60%	0.6%
Exit costs	We do not charge an exit fee if you hold to maturity	0.0%
Ongoing costs taken each year
Management fees and other administrative or operating costs	None	0.0%
Transaction costs	None	0.0%
Incidental costs taken under specific conditions
Performance fees	None	0.0%

Use the descriptions and column headings prescribed in RTS Annex VII; the rows above summarise them in original words.

5. Key information document draft

The section titles below follow PRIIPs Regulation Article 8 and the RTS. Text in square brackets is to be completed; sentences marked (Prescribed text: RTS) are to be copied from the relevant RTS annex in the language of the KID, not from this template.

5.1 Key Information Document

Purpose. (Prescribed text: RTS, purpose statement explaining that the document provides key information about the product, is not marketing material and is required by law.)

5.2 Product

Item	Content (Example)
Name of the product	Kestrel Bay Euro Equity Participation Note 2031
Identifier	[ISIN]
PRIIP manufacturer	Fernhollow Bank, [website], call [telephone number] for more information
Competent authority responsible for supervising the manufacturer in relation to this KID	[Name of competent authority]
Date of production of the KID	YYYY-MM-DD

Comprehension alert (where applicable under Article 8(3)(b)): (Prescribed text: Regulation Art. 8(3)(b), warning that the product is not simple and may be difficult to understand.)

5.3 What is this product?

Item	Content (Example)
Type	Unsecured senior preferred note issued by Fernhollow Bank, governed by [law]
Term	Fixed maturity on 2031-12-15. Fernhollow Bank cannot terminate early except on the events in the final terms, such as illegality
Objectives	The note gives you 70% of the rise of [index name] between 2026-12-15 and the final valuation date. If the index falls, you receive at least 90% of the nominal at maturity. You do not receive dividends from the index shares. The floor applies only at maturity and only if Fernhollow Bank can pay.
Intended retail investor	Investors with knowledge of capital-floor notes or similar products (or advised or in portfolio management), who can bear a loss of up to 10% at maturity and up to 100% if the issuer defaults or is bailed in, who seek equity-linked growth with a partial floor over five years and intend to hold to maturity
Insurance benefits	Not applicable

5.4 What are the risks and what could I get in return?

Risk indicator. Show the 1 to 7 scale with class 3 highlighted, the RHP assumption and the prescribed explanation. (Prescribed text: RTS Annex III, explanation of the SRI, the assumption that the product is kept for the RHP, and the warning that the actual risk can vary if cashed in early.)

Example: "We have classified this product as 3 out of 7, which is a medium-low risk class." Add the narrative on risks not captured by the SRI: the early exit price is not protected by the floor and depends on the index, interest rates and the issuer's credit spread; you could lose up to 10% of your investment at maturity, and all of it if Fernhollow Bank is unable to pay.

Performance scenarios. Present the table from section 3.2 in the layout of RTS Annex V, with the prescribed statements on what the figures include, that the stress scenario shows what you might get back in extreme market circumstances, and that the outcome depends on future market performance, which is uncertain.

Recommended holding period: 5 years. Example investment: EUR 10,000		If you exit after 1 year	If you exit after 5 years
Minimum	You could lose some of your investment at maturity (minimum EUR 9,000 if Fernhollow Bank pays) and some or all of it on early exit
Stress	What you might get back after costs; average return each year	EUR 7,120; -28.8%	EUR 9,000; -2.09%
Unfavourable	What you might get back after costs; average return each year	EUR 8,850; -11.5%	EUR 9,000; -2.09%
Moderate	What you might get back after costs; average return each year	EUR 9,880; -1.2%	EUR 11,260; 2.40%
Favourable	What you might get back after costs; average return each year	EUR 10,950; +9.5%	EUR 13,150; 5.63%

5.5 What happens if Fernhollow Bank is unable to pay out?

Example: You are exposed to the risk that Fernhollow Bank fails to meet its obligations under the note, for example in insolvency or if a resolution authority writes down or converts the note under the bank resolution rules (bail-in). This could cause you to lose some or all of your investment. The note is not a deposit and is not covered by any deposit guarantee or investor compensation scheme.

5.6 What are the costs?

Insert the "Costs over time" and "Composition of costs" tables from sections 4.2 and 4.3 with the prescribed introductory sentences (Prescribed text: RTS Annex VII), and state that the person advising on or selling the product may charge other costs and must tell you about them.

5.7 How long should I hold it and can I take money out early?

Example: Recommended holding period: 5 years, until maturity on 2031-12-15. The product is designed to be held to maturity. Fernhollow Bank intends to quote a daily bid price in normal market conditions, with a target spread of about 1%, but is not obliged to do so. If you sell before maturity, you receive the market price, which may be significantly below 90% of the nominal, and the floor does not apply.

5.8 How can I complain?

Example: Send a complaint about the product or the conduct of Fernhollow Bank to [postal address], [email address] or via [website complaints page]. Complaints about the person who advised on or sold you the product go to that person. The manufacturer's complaint procedure is set out in [document reference].

5.9 Other relevant information

Example: The prospectus, any supplements and the final terms are available free of charge at [website]. The distributor will give you its own information on costs and charges under MiFID II. List here only information the investor may want; do not use this section to add content that belongs elsewhere in the KID.

6. Review, revision and publication

The RTS require the manufacturer to review the information in the KID whenever there is a change that significantly affects or is likely to affect it, and at least every twelve months, and to revise it promptly where the review shows a change (RTS Articles 15 and 16; check the consolidated text). Changes in the SRI class and material changes in performance scenarios or costs are typical triggers.

Review ID	Trigger	Date	SRI	Scenarios changed	Costs changed	Outcome
KID-REV-001 (Example)	Scheduled 12-month review	YYYY-MM-DD	3 (unchanged)	Yes, market data update	No	Revised KID 1.1 published
KID-REV-002 (Example)	Issuer downgrade by two notches (TMA trigger TRG-001)	YYYY-MM-DD	Re-run CRM	[ ]	[ ]	[Outcome]

Publication: post the current KID on the manufacturer's website in a place easy to find, keep previous versions with their production dates, and notify distributors of every revision.

7. Delivery and record keeping

Channel	Delivery method	Timing	Evidence	Owner
Branch advice (Example)	Paper copy or durable medium, free of charge	Before the order is placed	Signed acknowledgement in the advice file	[Distributor]
Online non-advised (Example)	Download step before the order button, with website link	Before the order is placed	System log of the KID version shown	[Distributor]
Telephone (Example)	Sent on durable medium; where the rules allow, provided after the transaction with the investor's consent	As the rules on distance sales permit (Art. 13(3))	Call record and consent	[Distributor]

Check PRIIPs Regulation Articles 13 and 14 for the conditions on media (paper, durable medium other than paper, website) and the conditions for delivery after the transaction.

8. Quality checks and sign-off

Check ID	Check	Result (Example)
KID-CHK-01	KID fits within three sides of A4 when printed	Passed, 3 pages
KID-CHK-02	Section titles and order match the Regulation and RTS	Passed
KID-CHK-03	SRI, scenarios and cost figures equal the workbook outputs	Passed
KID-CHK-04	Scenario values net of all costs; costs table uses the moderate scenario	Passed
KID-CHK-05	Consistency with the prospectus, final terms and marketing material	Passed
KID-CHK-06	Intended retail investor matches the target market assessment	Passed, TMA-2026-007
KID-CHK-07	No marketing language, no cross-reference needed to understand the KID	Passed
KID-CHK-08	Translations checked by a qualified reviewer for each language	Open for [language]

9. Reform watch and jurisdiction notes

Jurisdiction	Regime	Status as of 2026-10 (check the official source)
EU	Regulation (EU) No 1286/2014 and Delegated Regulation (EU) 2017/653 as amended by (EU) 2021/2268	In force; UCITS have had to provide a PRIIPs KID instead of the UCITS key investor information document since 2023-01-01
EU reform	Retail Investment Strategy: a regulation amending the PRIIPs Regulation, alongside an omnibus directive	Provisional political agreement on 2025-12-18; the Council's committee of permanent representatives was asked to confirm the final compromise text in June 2026. Commentary expects the PRIIPs changes to apply about 18 months after publication in the Official Journal. Proposed changes include a shorter KID with a "product at a glance" summary; check the adopted text before changing the layout
UK	FCA Consumer Composite Investments (CCI) regime, PS25/20 (8 December 2025), replacing UK PRIIPs and UK UCITS disclosures	Firms may use the new product summary from 2026-04-06; the CCI rules apply in full from 2027-06-08
US	No KID equivalent; registered funds use a summary prospectus under SEC Rule 498 (17 CFR 230.498) and structured notes use prospectus and pricing supplement disclosure	Check SEC rules for the product type

10. Glossary and references

Term	Meaning
PRIIP	Packaged retail and insurance-based investment product
KID	Key information document under the PRIIPs Regulation
RTS	Regulatory technical standards; here Delegated Regulation (EU) 2017/653 as amended
SRI	Summary risk indicator, 1 (lower risk) to 7 (higher risk)
MRM, CRM	Market risk measure (1 to 7) and credit risk measure (1 to 6)
VEV	VaR-equivalent volatility, used to set the MRM class
RHP	Recommended holding period
Annual cost impact	Reduction in yield: the difference between the average annual return before and after costs
Bail-in	Write-down or conversion of liabilities by a resolution authority

References (cited by number and title; obtain the official text):

Regulation (EU) No 1286/2014 on key information documents for packaged retail and insurance-based investment products (PRIIPs), Articles 2, 4 to 8, 10, 11, 13, 14 and 19. EUR-Lex: https://eur-lex.europa.eu/eli/reg/2014/1286/oj
Commission Delegated Regulation (EU) 2017/653 (PRIIPs RTS), Articles 1 to 18 and Annexes I to VIII. EUR-Lex: https://eur-lex.europa.eu/eli/reg_del/2017/653/oj
Commission Delegated Regulation (EU) 2021/2268 of 6 September 2021 amending the RTS on performance scenarios, cost presentation and other items (applying from 2023-01-01; corrigendum 2023-01-12). EUR-Lex: https://eur-lex.europa.eu/eli/reg_del/2021/2268/oj
Joint Committee of the ESAs, Consolidated questions and answers on the PRIIPs KID, JC 2023 22, 15 March 2024: https://eba.europa.eu/sites/default/files/2024-03/1441126b-3fab-4d77-a41b-9463770ab587/jc_2023_22_-_consolidated_jc_priips_qas.pdf
Financial Conduct Authority, PS25/20 Consumer Composite Investments, 8 December 2025.
Council of the EU and European Parliament, provisional agreement on the Retail Investment Strategy, 18 December 2025.

11. Standard and licence note

Based on Regulation (EU) No 1286/2014 and Commission Delegated Regulation (EU) 2017/653 as amended by Delegated Regulation (EU) 2021/2268, with the ESA consolidated Q&A (JC 2023 22) used for interpretation. EUR-Lex and ESA material is reused with acknowledgement; the prescribed KID section titles are reproduced as the law requires, articles and annexes are cited by number, and the prescribed sentences of the RTS annexes are not reproduced: copy them from the official text in the language of the KID. The structure, guidance, checks and the Kestrel Bay and Fernhollow Bank example are original; all names and figures are fictional and illustrative. Check the current consolidated texts and the status of the Retail Investment Strategy before use. This is a documentation format, not legal, investment or financial advice.

Template licence: MIT.

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