Regulatory outlook · AIFs · 2026–2028
The rulebook for
Alternative Investment Funds
is being rewritten.
Six sectoral frameworks — UCITS, AIFMD, MiFID II, IDD, Solvency II and PRIIPs — are being amended in parallel under the EU Retail Investment Strategy. SFDR Level 2 is moving. DORA is live. AIFMD II is transposing. The KID that was compliant in 2025 will not be compliant in 2027. Priqid's regulatory team tracks every amendment across the Level 1, Level 2 and RTS pipelines — and translates them into engine logic before they take effect.
The regulatory stack · 2026–2028
Eleven frameworks.
One calendar. No grace period.
The EU Retail Investment Strategy is the largest single piece of retail-investor legislation since PRIIPs itself. It arrives alongside AIFMD II transposition, SFDR Level 2 recalibration, the fully-live DORA regime, MiCA for tokenised funds, ESAP data ingestion, and the UK's parallel CCI reform. Each framework has its own Level 1 / Level 2 / RTS / ITS pipeline, its own effective date, and its own enforcement mechanism. Together they rewrite the obligations of every AIF marketed to retail investors.
Retail Investment Strategy
The Omnibus Directive amends UCITS V, AIFMD, MiFID II, IDD and Solvency II, with a direct amendment to the PRIIPs Regulation. Introduces the Value for Money obligation, ESMA peer-group benchmarks, Level 1 inducement proportionality test, and a fundamentally restructured KID.
Political agreement: 17 Dec 2025 · OJ publication: 2026 · Transposition: 24 months · Apply-date: 30 months (PRIIPs: 18)
AIFMD II
New liquidity-management-tool requirements, loan-origination fund rules, extended delegation oversight, revised Annex IV reporting, and substance expectations that directly reshape Category 3 AIFs within the scope of PRIIPs.
Entered into force: 15 Apr 2024 · Transposition deadline: 16 Apr 2026 · Reporting uplift: 2027
SFDR + Level 2 RTS
ESMA-EIOPA-EBA RTS revisions affect PAI indicators, DNSH disclosures and template structure. RIS introduces a new "How environmentally sustainable is this product?" section directly into the KID — bridging the SFDR regime into retail-facing disclosure.
Level 1 live · Level 2 revised RTS: phased through 2026–2027 · Categorisation reform: open consultation
DORA
Digital Operational Resilience Regulation applies to AIFMs and UCITS ManCos. Imposes ICT risk-management, incident reporting, resilience testing, and third-party provider oversight obligations — including on any external KID production infrastructure in use.
Apply-date: 17 Jan 2025 · RTS phased: 2025–2026 · Register of information: annual
PRIIPs Regulation
Direct amendment under the RIS Package. Machine-readable KIDs, real-time tailored variants, restructured templates to be republished by the ESAs, and integration with the ESMA/EIOPA online comparison tool. The 18-month apply-date is the shortest of any RIS component.
Current RTS: in force · RIS amendments apply: 18 months post-OJ · Machine-readable KID: extended 30-month window
ESAP
The European Single Access Point centralises regulatory disclosures. Manufacturers will be required to transmit product data — including KID data — to national competent authorities for onward ingestion. Machine-readable structure is the link between PRIIPs RIS amendments and ESAP.
First bodies: 2027 · Fund-related disclosures: phased through 2028–2030
MiCA
Markets in Crypto-Assets Regulation affects AIFs with tokenised units or crypto-asset exposure, creating a parallel disclosure regime. Relevant where KID scope overlaps with crypto-asset service provider obligations.
Fully live: 30 Dec 2024 · Transitional regimes: ending 2026
UK Consumer Composite Investments
The FCA's parallel reform replaces PRIIPs KID and UCITS KIID with a flexible "Product Summary" document. New 1–10 risk scale replaces the SRI; implicit transaction costs no longer disclosed; 10 years of historical volatility required; costs denominated in GBP.
Final rules published: 8 Dec 2025 · Voluntary apply-date: 6 Apr 2026 · Mandatory: 8 Jun 2027
The Priqid-critical section · PRIIPs KID changes
The KID you produce today
will not be the KID the regulator expects tomorrow.
Under the RIS Package, the structure of the Key Information Document is being materially rewritten. New sections are introduced, existing disclosures are removed, the maximum page count is reduced, delivery must be machine-readable and interactive, and the ESAs will republish the underlying templates. The below is the confirmed delta against the current RTS, consolidated from the political agreement text and downstream Level 2 signalling.
Four-page maximum format
The KID moves to a four-page document. Rearrangement of sections, consolidation of cost tables, and suppression of redundant risk disclosures required across every in-scope fund.
"Product at a glance"
A new summary section at the top of the document presenting the core cost and risk metrics in a highly-visible format. Positioned before the existing risk-and-reward section.
"How environmentally sustainable is this product?"
A mandatory sustainability disclosure section bridging the SFDR regime into the PRIIPs KID. Level 1 introduces the reference; Level 2 will define the scope and format. Every AIF with retail investors is in scope regardless of Article 6 / 8 / 9 status.
The comprehension alert
The existing warning — "You are about to purchase a product that is not simple and may be difficult to understand" — is removed from the top of the KID under the RIS amendments.
Machine-readable, interactive KID
KIDs must be produced in machine-readable form (though not fully data-extractable) with expandable sections to reduce visual overload. Extended 30-month implementation runway following entry into force.
Tailored real-time KID variants
Real-time tailored versions of the document varying by amount invested and investment horizon. Shifts the KID from a static publication to a dynamic output requiring engine-based regeneration per distribution context.
ESAs to republish KID templates
Updated KID templates will be developed and made available by European supervisory authorities. Every existing KID is effectively re-baselined; fund managers cannot migrate by amendment alone.
ESMA/EIOPA online comparison tool
Product data (including KID data) transmitted by manufacturers and distributors to national competent authorities for ingestion into a pan-EU online comparison tool. Downstream of ESAP operation.
EPT / EMT v4.3 cycle
The European PRIIPs Template and European MiFID Template continue their version cycle in parallel with the RIS amendments. v4.3 updates are being finalised; downstream versions will reflect Level 2 RIS requirements once published.
The enforcement mechanism · Value for Money
For the first time,
a regulator can prevent a fund from being marketed.
The Value for Money regime is the most structurally significant change in the RIS package. It moves product governance from a process obligation to an outcome obligation, anchored in ESMA-published peer-group benchmarks and a continuous remediation duty. Deviation from benchmark — without a documented additional test — triggers a direct marketing ban to retail investors.
“If there is a deviation from the relevant benchmark, it must not be marketed to retail investors by the investment fund manager, unless it is justified by additional tests.”
— On the RIS Value for Money framework
“UCITS ManCos and AIFMs are required to maintain, operate, and review an effective pricing process that can accurately identify and measure all costs borne by the investment fund or its unitholders.”
— On the AIFMD / UCITS uplift
“Fund managers should expect a more explicit, measurable and continuous VfM obligation — with peer-group VfM assessments becoming a part of product governance arrangements.”
— On the Level 2 direction of travel
This is not a disclosure regime — it is a marketability regime. Funds that cannot evidence cost and performance alignment with the applicable ESMA peer group lose retail-market access until remediated. The implication for KID production is that every input assumption, benchmark selection, and cost calculation must be traceable to a documented methodology capable of surviving peer-group scrutiny.
The 2026–2028 calendar
What applies, when.
A consolidated view of the Level 1 apply-dates, transposition deadlines, and Level 2 / RTS expected publication windows relevant to AIFs marketed to retail investors. Dates are derived from published Commission / Council / Parliament communications and ESMA / EIOPA work programmes. Timelines where Level 2 is still in negotiation are flagged as provisional.
Political agreement on the RIS Package
Council and Parliament reach agreement closing negotiations that began with the Commission's proposal of 24 May 2023. Technical finalisation of text follows in Q1 2026.
DORA apply-date
Digital Operational Resilience Regulation applies to UCITS ManCos and AIFMs. Third-party ICT provider oversight obligations now enforceable.
UK FCA publishes final CCI rules
Consumer Composite Investments framework finalised. Voluntary apply-date 6 April 2026; mandatory 8 June 2027. New 1–10 risk scale replaces the PRIIPs SRI for UK-distributed products.
AIFMD II Member State transposition deadline
National implementing measures must be adopted across EU 27. Liquidity management tools, loan-origination fund rules, and revised Annex IV reporting become enforceable at Member State level.
RIS Package published in the Official Journal
Entry into force triggers the 18-month countdown for PRIIPs amendments and the 24-month Member State transposition window for the wider Omnibus Directive.
ESAP first bodies begin reporting
The European Single Access Point begins ingesting disclosures from the first wave of obliged entities. Fund-specific ingestion phases follow through 2028–2030.
PRIIPs RIS amendments apply
Eighteen months after OJ publication, the restructured KID becomes the compliant standard. New sections, four-page limit, machine-readable delivery, tailored variants, and re-issued ESA templates all take effect.
Full RIS Omnibus applies
Thirty months after entry into force, Value for Money peer-group benchmarks, inducement proportionality at Level 1, the new suitability test, and the ESMA/EIOPA online comparison tool integration all become enforceable obligations.
How Priqid tracks this
Built to be faster than the rulebook.
Priqid is not a KID document factory. It is a compliance engine with regulation monitoring at its core. Every amendment at Level 1, Level 2 and RTS level enters a tracked change pipeline — from EUR-Lex publication through ESA technical advice through national transposition — and is reflected in the engine logic before the effective date. When the rulebook moves, your KIDs move with it, with a full audit trail for the regulator.
01
Continuous monitoring
EUR-Lex, ESMA, EIOPA, CSSF, BaFin, AMF and FCA feeds continuously monitored. Level 1 and Level 2 changes parsed, assessed, and scheduled against the engine's release cycle.
02
Traceable methodology
Every calculation in every KID references the specific RTS article from which it derives. When the RTS changes, the reference is updated and the KID is flagged for review — no black box, no consultant memo.
03
Machine-readable by default
Every KID produced by the engine is machine-readable from the outset — aligning with the RIS amendments and the downstream ESAP ingestion requirements without a separate migration project.
Get started with Priqid
Your KID is a moving target.
Stop chasing it.
Priqid produces defensible, regulation-current KID documentation — and the engine maintains it as the rulebook evolves. Talk to us about moving your fund range onto the engine.