In its current form, the Retail Investment Strategy (RIS) will not achieve its goal of making investing more accessible to European citizens and could deter, rather than encourage, retail participation. In order to stand a chance of delivering on its objectives, the RIS needs urgent simplification. EFAMA have produced a short leaflet with our recommendations on how to simplify and reduce complexity in the current proposal.

Our key suggestions include:

• Delete the Value for Money (VfM) benchmarks, which impose a one-size-fits-all, overly cost focused framework that does not reflect the diversity of European products. Instead, the RIS should rely on the existing MiFID II product governance and consider using peer group assessments, across the whole value chain, to determine whether products provide VfM.
• Simplify the investor journey by eliminating redundant tests and excessive disclosures, which currently make investing overly complex and discourages retail investors.
• Focus on relevant disclosures emphasising key benefits like ESG characteristics, qualitative features that drive investment decisions, and the importance of investing with a long-term horizon.
• Avoid additional reporting requirements, and instead leverage existing data sources like PRIIPs KID data and the European Single Access Point.

• Eliminate gold plating requirements, which create fragmentation and prevent a unified Savings and Investments Union.