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European Insurance and Occupational Pensions Authority
 

3458

Q&A

Question ID: 3458

Regulation Reference: (EU) 2019/1238 - Pan-European Personal Pension Product (PEPP)

Topic: Disclosure (Art. 26 – 33, 35 - 39 PEPP)

Article: Annex III, Part 3, Section 29 of the Commission Delegated Regulation 2021/473

Status: Final

Date of submission: 10 Nov 2025

Question

We would like to clarify the interpretation of Annex III, Part 3, Section 29 which provides that, “where necessary, these amounts may be calculated as the average total annual costs over the term of the PEPP contract. The calculation of the compound effect of the costs shall be based on a 40 years’ accumulation period, based on monthly contributions of EUR 100 and on the projected accumulated capital in the best estimate scenario.” Should this 40-year methodology be always applied when presenting total annual costs in Section 4 of the KID PEPP (“What are the costs”), particularly in the subsection showing total annual costs expressed in monetary and percentage terms or shall the costs in this column be calculated as total annual costs incurred and chargeable within 12 months, expressed both in monetary terms and as a percentage of the projected accumulated capital after 12 months, based on monthly contributions of €100 in the best estimate scenario? If the costs shall be calculated as total annual costs incurred and chargeable within 12 months, is it allowed to base the calculation solely on the first 12 months of saving, i.e., with total contributions amounting to 1,200 euros at the end of the 12 months?

EIOPA answer

In the PEPP KID section 'What are the costs' costs have to be provided in a brief, clear and easily understandable manner, as set out in Article 5(1) of the PEPP Delegated Regulation 2021/473. Practically, Article 5(1) mandates costs to be represented according to Annex III of the same regulation. Within Annex III, Part 3, Section 29, it is mandated that total costs are expressed as a percentage of the projected accumulated capital and in monetary terms after a 12-month period.

It would be necessary for PEPP providers to express the total costs as total average annual costs over the term of the PEPP when the costs are largely calculated based on a variable that changes throughout the term of the PEPP, such as expected returns and the related total accumulated capital. In these cases, not taking into account the total term of the PEPP, e.g., only calculating the costs based on the first year of contract, risks not being clear and understandable to perspective PEPP savers as the costs can vary significantly throughout the term of the PEPP.