Official PRIIPs Position on the Application of the Act Implementing Regulation (EU) No 1286/2014 on Key Information Documents for Packaged Retail and Insurance-based Investment Products to Certain Types of Bonds

Croatian Financial Services Agency, 10000 Zagreb, Franje Račkoga 6, P.O. Box 164, Croatia t: 01 6173 200, f: 01 4811 507, e: info@hanfa.hr, OIB: 49376181407, MB: 02016419, w: www.hanfa.hr

The Croatian Financial Services Agency (hereinafter: Hanfa), for the purpose of promoting, organizing and supervising measures for the effective functioning of financial markets, with a view to harmonizing the conduct of market participants, based on Article 15(4) of the Act on the Croatian Financial Services Agency (Official Gazette NN 140/05, 12/12), at the meeting of the Management Board held on 29 August 2025, has adopted

OFFICIAL POSITION on the application of the Act Implementing Regulation (EU) No 1286/2014 on Key Information Documents for Packaged Retail and Insurance-based Investment Products to certain types of bonds

I. On 24 October 2019, the European supervisory authorities (EBA, EIOPA and ESMA) adopted Joint Committee Statement JC 20194 (Joint ESA Supervisory Statement – Application of scope of the PRIIPs Regulation to bonds, hereinafter: Joint Statement), which was issued with the aim of reducing the risk of inconsistent application of Regulation (EU) No 1286/2014 of the European Parliament and of the Council of 26 November 2014 on packaged retail and insurance-based investment products (PRIIPs) (hereinafter: PRIIPs Regulation) among national competent authorities regarding the determination of types of bonds offered to retail investors for which a key information document (hereinafter: KID) must be drawn up. The Joint Statement essentially provides guidelines for the application of PRIIPs Regulation provisions to various bond features, in order to ensure a consistent level of protection for retail investors and harmonized rules across the EU single market.

II. By Article 4 of the Act Implementing Regulation (EU) No 1286/2014 on Key Information Documents (Official Gazette NN 112/18, 123/23, hereinafter: PRIIPs Implementation Act), Hanfa was designated as the competent authority for implementing the PRIIPs Regulation. Within its powers under Article 6 of the PRIIPs Implementation Act, Hanfa applies the requirements of the PRIIPs Regulation for consumer protection in the same manner as set out in the Joint Statement, and holds the position that all obligations under the PRIIPs Regulation and the PRIIPs Implementation Act apply to bonds with features specified in the Joint Statement, as well as to issuers of such bonds and persons selling or offering them to retail investors. This includes, among other things, the obligation of issuers of bonds that have features defined in the Joint Statement of European supervisory authorities, and which are offered to retail investors, to:

1. draw up a key information document in accordance with the provisions of the PRIIPs Regulation; and
2. publicly publish such document on its website and deliver it to retail investors prior to the purchase of such bond, in accordance with the obligations under Articles 5 and 13 of the PRIIPs Regulation.

Furthermore, Article 5(2) of the PRIIPs Regulation provides that each Member State may request prior notification of a key information document from a PRIIP issuer or a person selling the PRIIP to the competent authority for PRIIPs placing it on the market in that Member State. Hanfa receives such notification pursuant to Article 12 of the PRIIPs Implementation Act. In accordance with the above, notifications to Hanfa are submitted via the email address priips@hanfa.hr no later than on the day of publication of the key information document on the website of the issuer or the person selling the PRIIP, and in any case before the PRIIP becomes available to retail investors in the Republic of Croatia.

CLASS: 008-02/21-03/01 REFERENCE NO.: 326-01-70-72-25-17 Zagreb, 29 August 2025

CHAIRMAN OF THE MANAGEMENT BOARD dr. Ante Žigman, PhD