Insurance Europe

Clear and accurate product information is vital to enabling consumers to make an informed choice. However, recent rules on consumer information have been discussed in isolation, which has led to a complex and confusing legislative architecture. Not enough attention has been paid to the combined effects and potential unintended consequences of these information requirements such as an information overload for consumers, incoherent disclosures and duplicative requirements.

The proposed changes to the Package Retail and Insurance-based Investment Products Regulation (PRIIPs) as part of the Retail Investment Strategy, will only address current shortcomings in EU disclosure rules if amendments address the current complexity of information and are based on thorough, holistic consumer testing that demonstrates improvements in customer’s understanding.