EFAMA commented on the current VAT rules for financial services and their functioning, as well as on possible changes to these rules, in a public consultation of the European Commission.

EFAMA agrees in principle with many of ESMA’s suggested approaches in their consultation on guidelines on certain aspects of the MIFID II appropriateness and execution-only requirements. However, certain, essential elements still require further considerations before finalising these Guidelines.

EFAMA welcomes the ESAs’ official approval of the revised PRIIPs RTS and is now awaiting the Commission’s endorsement to have the RTS approved by the European co-legislators.

Originally, the Commission had intended to endorse the revised RTS by Q1 2020. With less than nine months remaining until the 31 December 2021 implementation deadline, there is now simply not enough time for fund managers and other product manufacturers to properly implement the envisaged wide-ranging changes. We explain why in more detail below.