2026-05-01
The Danish Financial Supervisory Authority ordered Imbro A/S to recalculate and update the result scenarios in its PRIIP Key Information Documents to include legally mandated cost tables, and to immediately remove all marketing materials displaying expected returns that deviate from the moderate scenario. The directive addresses instances where the fund manager incorrectly calculated stressed scenarios as yielding positive returns and promoted funds with significantly higher advertised returns than those documented in the official KIDs. This enforcement action aims to prevent retail investors in the IMBRO ZERO2 BATTERY STORAGE 1 P/S and IMBRO RETAIL – FREDERIKSHAVN P/S and A/S funds from being misled about potential investment outcomes.
Decision 01-05-2026 On 29 April 2026, the Danish Financial Supervisory Authority (Finanstilsynet) ordered Imbro A/S to recalculate and update the result scenarios in the PRIIP KID and to ensure that they contain the legally required cost tables. The company must also remove all misleading marketing. Imbro A/S manages the funds IMBRO - ZERO2 BATTERY STORAGE 1 P/S as well as IMBRO RETAIL – FREDERIKSHAVN P/S and A/S. These funds are alternative investment funds targeting retail investors with a minimum investment of DKK 750,000. Therefore, Imbro A/S must prepare and provide accurate Key Information Documents (PRIIP KID) to investors.
In one instance, Imbro A/S incorrectly calculated the result scenarios in the PRIIP KID, such that even the stressed result scenario showed positive returns. Furthermore, Imbro A/S marketed a fund with significantly higher returns than those stated in the corresponding PRIIP KID. There is therefore a risk that investors in these funds will be misled regarding the results the funds can be expected to deliver.
Managers of alternative investment funds are required to prepare non-misleading PRIIP KIDs and ensure that all marketing complies with the information in this document.
The Danish Financial Supervisory Authority has therefore ordered the company to recalculate and update the result scenarios in the PRIIP KID and to ensure that they contain the legally required cost tables.
[1]
The Danish Financial Supervisory Authority has also ordered the company to immediately remove all misleading marketing that shows an expected return different from the moderate scenario in the PRIIP KID. [2]
[1] Ref. Article 6(1) of Regulation (EU) No 1286/2014, in conjunction with Annex IV, paragraphs 21-28, of Regulation (EU) No 2017/653
[2] Ref. Article 9 of Regulation (EU) No 1286/2014
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