EU Retail Investment Strategy: From Political Agreement to Data Implementation

The EU Retail Investment Strategy (RIS) is moving from political agreement towards detailed implementation design. 

The most significant recent milestone came on 24 August 2026, when the European Commission formally requested technical advice from the European Securities and Markets Authority (ESMA) on the implementation of RIS amendments to the Markets in Financial Instruments Directive II (MiFID II), the Undertakings for Collective Investment in Transferable Securities Directive (UCITS Directive) and the Alternative Investment Fund Managers Directive (AIFMD).

This marks the start of the process that will ultimately define the detailed rules firms must operationalize (European Commission's request).

The direction of travel is now clear. For the financial industry,  RIS is fundamentally a data and classification challenge.

Three areas stand out in particular:

1. Value for Money (VfM).
2. MiFID II suitability and appropriateness classifications.
3. Packaged retail and insurance-based investment products (PRIIPs) disclosures.

The centrepiece of the RIS is the new Value for Money framework.

The agreed text strengthens the existing product governance framework of MiFID II, and the rules of conduct under AIFMD and UCITS Directive, by adding an obligation for investment firms to assess the ‘value for money’ (‘VfM’) of packaged retail and insurance-based investment products (PRIIPs) they manufacture or distribute to retail clients, and for UCITS and AIFs they manage (RIS legislative Train Schedule).

This includes assessing costs, charges, performance and benefits, as well as comparing products against peer groups of similar products.

The Commission has described VfM as a genuinely new concept, and has asked ESMA to provide an in-depth, evidence-based justification for the criteria it proposes. Where a product is found to be an outlier against its peer group to the detriment of the retail client, firms will need to make changes to the product or, ultimately, withdraw it from the market.

For asset managers, fund distributors and wealth managers, this creates a need for significantly richer and more standardized data. Compliance will require not only costs and charges information but also comparative datasets, peer-group classifications and supporting evidence for product governance processes.

This moves along partially similar lines to the fair-value assessments introduced under the UK Consumer Duty.

FinDatEx subsequently added UK-specific value-for-money fields to version 4.1 of the European MiFID Template (EMT). 

A second area of direct impact concerns the MiFID II suitability and appropriateness regime. The Commission's request for technical advice asks ESMA to address two related but distinct classification questions.

The first is the existing criteria for identifying “other non-complex financial instruments” for the purposes of the appropriateness assessment framework.

The second, and new, question is how to define financial instruments that qualify as “well-diversified, non-complex and cost-efficient” for the purposes of a newly introduced “simple advice” regime, under which firms would not need to assess a client's knowledge and experience before making a recommendation.

Although the final technical standards are not yet available, the RIS implementation process creates a strong likelihood that both classification exercises will need to be revisited in parallel, and that firms will need to track how the two interact.

Even relatively small changes to either definition could cascade into client onboarding, appropriateness testing, digital advisory tools and distribution controls.

For many financial institutions, this will mean reviewing thousands of instruments and potentially adjusting suitability and appropriateness workflows to accommodate both the existing non-complex exemption and the new simple advice qualifying test.

The third major area impacted by RIS is PRIIPs, although PRIIPs is not part of the European Commission’s request for technical advice to ESMA.

The RIS package includes substantial reforms to the PRIIPs regime aimed at making Key Information Documents (KIDs) more understandable, comparable and easier for retail investors to use. The broader objective is to improve investment decision-making while supporting digital distribution channels.

One of the most important long-term implications is the growing emphasis on structured and machine-readable regulatory information.

Industry discussions increasingly point towards more standardised, digital disclosure formats that can be consumed by comparison tools, advisory platforms and automated compliance systems.

On the Commission's current planning assumptions, the RIS is not expected to apply before around July 2029, although the PRIIP rules follow a different timetable.

However, the most important phase for industry participants has already begun. The Commission's call for advice means that ESMA will now define many of the practical details that determine how Value for Money assessments, suitability and appropriateness requirements, and disclosure obligations function in practice.

The key question is therefore no longer whether RIS will affect data products, but how extensive those changes will be.

Value for Money frameworks will require new fund and PRIIPs data and benchmarking capabilities.

Revisions to the suitability and appropriateness regime may drive changes to both the non-complex instrument exemption and the new simple advice classification.

PRIIPs reforms will continue the shift towards structured, machine-readable regulatory disclosures.

Reviewing existing data coverage for costs, charges, performance and product benefits is the starting point. Identifying gaps in current suitability, appropriateness and non-complex instrument classifications is also pivotal.

Finally, assessing whether existing systems can support peer-group construction and product benchmarking is likely to be a major challenge.

In short, RIS is evolving from an investor protection initiative into a significant data management challenge, creating both implementation challenges and new opportunities for the financial industry.

SIX is actively preparing to support clients through this transition. Given the scale and complexity of the upcoming changes, close collaboration with market participants will be key to facilitating a smooth and effective implementation.