Ireland: Central Bank Confirms PRIIPs KID Filing Requirements For UCITS And AIFs From 1 January 2024

On 27 November 2023, the Central Bank of Ireland (the "Central Bank") published the 40^th Edition of the UCITS Q&A. The 40^th Edition revises Q&A ID 1109 to clarify that from 1 January 2024, UCITS authorised prior to 1 January 2023 that are required to provide a PRIIPs KID should submit the PRIIPs KID to the Central Bank through the Central Bank Portal (the "Portal") under the section "Investment Funds – Ad Hoc returns" in accordance with the guidance on the Central Bank's website. Further guidance on PRIIPs filing requirements can be found here.

Where a UCITS produces both a UCITS KIID and PRIIPs KID, the latest versions of both should be filed with the Central Bank through the Portal.

Where a PRIIPs KID that has been previously submitted to the Central Bank is updated, the amended PRIIPs KID should be submitted to the Central Bank through the Portal.

The Central Bank also published the 49^th Edition of the AIFMD Q&A. The 49^th Edition revises existing Q&A ID 1126 to clarify that where an AIF is required to produce a PRIIPs KID, this should be filed through the Portal under the section "Investment Funds – Ad Hoc returns" from 1 January 2024 in accordance with the Central Bank's guidance on the filing of a PRIIPs KID.

The 49^th Edition of the AIFMD Q&A also includes the publication of three new Q&As (IDs 1157, 1158 and 1159) which consider what is permissible when a RIAIF/QIAIF invests through a subsidiary.

This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.