Consumer Information

Pension products more than an investments

What information do consumers require to buy a financial product? The European Commission addresses this question with a proposal for a Regulation on Packaged Retail Investment Products (PRIPs). The GDV welcomes the intention to provide for uniform information requirements for PRIPs vis-à-vis consumers. However, the different characteristics of all products defined as PRIPs should be taken into account. The focus must be on the actual comparability of products, the current proposal does not yet meet this objective.

The scope of the proposal includes products which do not constitute typical PRIPs. Among others, pension products and life insurances would be treated like investment products. GDV considers this as inappropriate and emphasizes that pension products should be excluded from the regulation. Any comparability of products covering different product groups and meeting different investment targets, from short-term speculation to lifelong old-age provision, is not feasible

Any uniform brief information covering these different product groups (“one size fits all”) would be a qualitative setback compared to more specific solutions already found. Also, PRIPs should be regulated through a Directive rather than through the proposed legal act of a regulation, thus making it possible to adjust national law to EU requirements in a more flexible manner.

The GDV’s complete position paper is available in the download section.


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on the proposal of the European Commission for a Regulation on key information documents for investment products