Implementation of the PRIIPs Act in Norway
This update concerns the Norwegian implementation of the PRIIPs Act.

Background
On 1 October 2024 the Norwegian implementation of the EU regulation 1286/2014 on key information documents for packaged retail and insurance-based investment products (the “PRIIPs Act”) will enter into force, which will impact both Norwegian and non-Norwegian fund managers marketing their funds towards non-professional investors in Norway.
Key proposals
The implementation requires any manufacturer of a packaged retail and insurance-based investment product (a “PRIIP”) to provide all non-professional investors with a Key Information Document (a “KID”). The definition of a PRIIP is as follows:
- an investment where, regardless of the legal form of the investment, the amount repayable to the retail investor is subject to fluctuations because of exposure to reference values or to the performance of one or more assets which are not directly purchased by the retail investor, or;
- an insurance product which offers a maturity or surrender value and where that maturity or surrender value is wholly or partially exposed, directly or indirectly, to market fluctuations.
The KID must be an accurate, fair, and clear representation of the terms and conditions of the PRIIP, written in Norwegian and not longer than three A4 pages. It must contain detailed sections on the following:
- Product description
- Risk description
- Costs associated with investin
- Lock-up period
- Complaints procedure
The KID needs to be updated regularly, at least annually, and must be written in a standardized format with pre-determined headings. The need to provide a KID updates the previous requirement outlined in the Norwegian AIFM Act to provide a “nøkkelinformasjonsdokument” to be further aligned with the rest of the EU, and to standardize the marketing approval process with the Norwegian Financial Supervisory Authority (the “NFSA”). The implementation of the PRIIPs Act further enables the NFSA to undertake a series of actions against managers that market AIF’s that do not comply with the requirements.
Subsequent phases
For existing PRIIP manufacturers that no longer market themselves towards new non-professional investors, this regulatory change should not affect them to an extent that they need to draft new KID’s. All PRIIP manufacturers that intend to, or continuously, market themselves to new non-professional investors will however need to comply with the new legislation from 1 October 2024.
Permian recommendation: All fund managers that intend to market funds to retail investors (including to semi-professional investors under the Euveca Regulation) should prepare a KID in compliance with the PRIIPs Act. For funds currently being marketed, please ensure that the KID is updated to comply with the standard.








