Official Position on the PRIIPs KID – English Language

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) received on 9 December 2025 a query regarding the interpretation of Article 13(2) of the Act on the Implementation of Regulation (EU) No 1286/2014 on packaged retail and insurance-based investment products (Official Gazette, Nos. 112/18 and 123/23, hereinafter: Act on the Implementation of the PRIIPs Regulation) and the possibility of using an exemption regarding the application of the English language in the key information document for packaged retail and insurance-based investment products for retail investors and insurance-based investment products upon their distribution. Given that the aforementioned query refers to the necessity of promoting, organizing and supervising measures for the effective functioning of financial markets in the sense of harmonizing the actions of supervisory authorities under Article 2(2) of the Act on the Croatian Financial Services Agency (Official Gazette Nos. 140/05, 154/11 and 12/12), Hanfa acts as follows: On the basis of Article 15(4) of the Act on the Croatian Financial Services Agency, Hanfa adopted at a meeting of its Management Board held on 12 March 2026 the OFFICIAL POSITION I. The key information document (hereinafter: KID) for packaged retail and insurance-based investment products for retail investors and insurance-based investment products (hereinafter: PRIIPs) distributed in the Republic of Croatia must, in accordance with Article 13(1) of the Act on the Implementation of the PRIIPs Regulation, be written in Croatian or translated into Croatian, in accordance with Article 7(1) 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) (Text with EEA relevance) (OJ L 352, 9.12.2014) (hereinafter: PRIIPs Regulation). The Act on the Implementation of the PRIIPs Regulation in Article 12(2) provides an exception to the aforementioned rule, which allows Hanfa to permit the use of another language in situations where it is evident that its application will not negatively affect the interests of retail investors to whom the product is distributed. II. Hanfa has been designated as the competent authority for the implementation of the PRIIPs Regulation under Article 4 of the Act on the Implementation of the PRIIPs Regulation. Therefore, within its competence and to ensure the effective functioning of the financial market while simultaneously safeguarding the interests of retail investors, Hanfa states its position that a PRIIP KID placed on the market, distributed or sold in the Republic of Croatia may be drawn up solely in English, i.e., it does not have to be drawn up in Croatian or translated into Croatian, but this is possible only upon fulfillment of a specific condition. 2 Namely, to ensure that the application of English in the KID does not negatively affect retail investors' interests, it must be ensured that the person placing on the market, selling or distributing a PRIIP in the Republic of Croatia must verify that the investor understands key financial terms in English for effective communication, and specifically understands the key features and risks of the PRIIP described in English, in accordance with the provisions of the PRIIPs Regulation. This can be verified, for example, based on a previously completed questionnaire on knowledge of English in the field of finance, which will be confirmed by the investor's signature. In this process, distributors and manufacturers must also adhere to other regulatory requirements, particularly regarding the target market assessment within the product governance process and suitability assessments for each investor in accordance with sectoral regulations. III. Independently of the above, we draw attention to the fact that if PRIIP marketing is conducted in the official language of the member state, according to Article 7(2) of the PRIIPs Regulation, the KID must be available in the same language. Thus, the use of an English-language KID in the Republic of Croatia is possible only if marketing activities for the product are not conducted in Croatian (or similar regional languages). The translation of the KID may be carried out by the product distributor. However, the KID translation must be published on the PRIIP manufacturer's website, and the manufacturer is responsible for the accuracy of such translation. Hanfa notes that this interpretation is subject to subsequent amendments, for example, due to different interpretations by ESMA. IV. This official position is published on Hanfa's website. CLASS: 008-02/21-03/01 REFERENCE NO.: 326-01-70-72-26-18 Zagreb, 12 March 2026. CHAIRMAN OF THE MANAGEMENT BOARD dr. sc. Ante Žigman