An asset management company is interested in launching a PEPP product based on robo-advisory software. They would launch the PEPP under an individual portfolio management model. This particular UCITS management company does not have a separate MIFID licence for individual portfolio management, but provides individual portfolio management as an additional service, as per the provisions of: The UCITS Directive (Art 6 par 3 point a of the Directive: “Member States may authorise management companies to provide, in addition to the management of UCITS, the following services: management of portfolios of investments, including those owned by pension funds, in accordance with mandates given by investors on a discretionary, client-by-client basis, where such portfolios include one or more of the instruments listed in Annex I, Section C to Directive 2004/39/EC;"…) Articles 13/2/a i 16/2 of the National Act on Open-Ended Investment Funds with a Public Offering, stating that the core activity of a UCITS management company is establishment and management of an UCITS fund, and that they can provide as an ancillary activity also portfolio management in accordance with the provisions of the legislation governing the capital markets; the UCITS management companies which pursue the business of portfolio management must - in addition to the provisions of the Act on Open-Ended Investment Funds with a Public Offering - also comply with the provisions of the legislation governing the capital markets (which is the national transposition of MiFID II). Under the PEPP Regulation, when a UCITS management company holds also a MIFID license for individual portfolio management it can provide PEPP also under this service. The scope of these provisions clearly allows a UCITS management company to offer PEPPs in the form of an individual portfolio management service if that UCITS management company has a separate MIFID license, and in this case it will follow MIFID rules. Our reading of the scope is also that a UCITS management company that does not hold a separate MIFID licence for portfolio management, but is licenced to provide individual portfolio management as an additional service under the UCITS Directive (art 6 par 3 point a of the Directive) and on the basis of national law (that transposed the UCITS Directive and MiFID II) can provide and offer PEPP structured as an individual portfolio management service. Do you agree with this interpretation?