{"id":9536,"date":"2026-04-01T15:20:38","date_gmt":"2026-04-01T13:20:38","guid":{"rendered":"https:\/\/becobra.be\/?p=9536"},"modified":"2026-04-17T10:32:32","modified_gmt":"2026-04-17T08:32:32","slug":"retail-investment-strategy-ris-april-2026-update","status":"publish","type":"post","link":"https:\/\/becobra.be\/en\/retail-investment-strategy-ris-april-2026-update\/","title":{"rendered":"Retail Investment Strategy (RIS) &#8211; April 2026 Update"},"content":{"rendered":"\n<p><strong>In early April 2026, it was confirmed that the interinstitutional technical discussions on the Retail Investment Strategy (RIS) have been concluded, following the political agreement reached at the end of 2025. The texts are now entering the final lawyer\u2011linguist review phase, ahead of formal adoption and publication.<\/strong><\/p>\n\n\n\n<p><strong>Becobra therefore publishes an updated analysis &#8211; below &#8211; clarifying:<\/strong><\/p>\n\n\n\n<ul class=\"wp-block-list\">\n<li>what is definitively settled by the political agreement, and<\/li>\n\n\n\n<li>which key points remain relevant during the implementation and supervisory phase.<\/li>\n<\/ul>\n\n\n\n<h2 class=\"wp-block-heading\"><strong>Retail Investment Strategy (RIS)<\/strong>: <strong>Context <strong>and key takeaways for insurance intermediaries<\/strong><\/strong><\/h2>\n\n\n\n<h5 class=\"wp-block-heading\"><em>Information note \u2013  for Becobra members<\/em><\/h5>\n\n\n\n<h4 class=\"wp-block-heading\"><strong><strong>1. What is the Retail Investment Strategy (RIS)?<\/strong><\/strong><\/h4>\n\n\n\n<p>The Retail Investment Strategy (RIS) is a European legislative package aimed at strengthening retail investors\u2019 participation in capital markets, while improving confidence, transparency and consumer protection throughout the investment journey.<\/p>\n\n\n\n<p>The RIS forms part of the European Union\u2019s broader objective to deepen and integrate capital markets, initially developed under the Capital Markets Union (CMU) and more recently reframed by the European Commission as the Savings and Investments Union (SIU), without changing its underlying objectives.<\/p>\n\n\n\n<p>From a regulatory perspective, the RIS consists mainly of:<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n<li>an Omnibus Directive amending several existing EU frameworks, notably the Insurance Distribution Directive (IDD) and MiFID II;<\/li>\n\n\n\n<li>a revision of the PRIIPs Regulation, with a strong focus on retail investor disclosures, presentation and comparability of information.<\/li>\n<\/ul>\n\n\n\n<p>While the RIS is primarily designed for retail investment activities, its reach extends beyond that segment. By amending horizontal distribution frameworks \u2013 in particular the IDD \u2013 it contributes to shaping the wider regulatory environment in which insurance intermediaries operate across different market segments.<\/p>\n\n\n\n<h4 class=\"wp-block-heading\"><strong><strong>2. Legislative context and current status<\/strong><\/strong><\/h4>\n\n\n\n<ul class=\"wp-block-list\">\n<li>The RIS package was published by the European Commission in May 2023.<\/li>\n\n\n\n<li>It has since been subject to extensive discussions within the European Parliament and the Council.<\/li>\n\n\n\n<li>A political agreement between the co\u2011legislators was reached at the end of 2025.<\/li>\n\n\n\n<li>Following this political agreement, the RIS has entered its final procedural phase, with consolidated compromise texts subject to lawyer\u2011linguist revision ahead of formal adoption and publication in the Official Journal.<\/li>\n\n\n\n<li>Once published, the new rules will apply only after lengthy transposition (24 months) and application (30 months) periods at national level.<\/li>\n<\/ul>\n\n\n\n<p>These developments confirm that the RIS is no longer a moving political dossier. The agreed framework is now fixed.<\/p>\n\n\n\n<h4 class=\"wp-block-heading\"><strong><strong>3. Why the agreed RIS framework is relevant beyond retail investment<\/strong><\/strong><\/h4>\n\n\n\n<p>Although retail investment products and services are at the core of the Retail Investment Strategy, the agreed RIS framework is relevant more broadly for insurance intermediaries.<\/p>\n\n\n\n<p>Through its amendments to the Insurance Distribution Directive (IDD) \u2013 which applies horizontally across the insurance market \u2013 the RIS reshapes key conduct\u2011of\u2011business concepts that structure the relationship between intermediaries and their clients. In particular, it reinforces expectations regarding:<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n<li><strong>inducements and remuneration models<\/strong>, and their compatibility with acting in the client\u2019s best interest;<\/li>\n\n\n\n<li><strong>value for money<\/strong>, as a guiding principle for product design, approval and distribution;<\/li>\n\n\n\n<li><strong>the investor journey<\/strong>, including the consistency between information, advice and distribution steps;<\/li>\n\n\n\n<li><strong>suitability and appropriateness assessments<\/strong>, as central elements of investor protection;<\/li>\n\n\n\n<li><strong>transparency and disclosure obligations<\/strong>, notably through revised PRIIPs requirements.<\/li>\n<\/ul>\n\n\n\n<p>Beyond the specific rules applicable to investment\u2011based products, the Omnibus Directive:<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n<li>amends general IDD provisions;<\/li>\n\n\n\n<li>touches upon horizontal conduct\u2011of\u2011business principles;<\/li>\n\n\n\n<li>and introduces concepts that are likely to influence supervisory practices and expectations over time.<\/li>\n<\/ul>\n\n\n\n<h5 class=\"wp-block-heading\"><strong><strong>Financial education and the broader policy narrative<\/strong><\/strong><\/h5>\n\n\n\n<p>Within the RIS, financial education appears as a contextual policy element supporting the overall retail investor protection narrative. The agreed text does not create new operational or compliance obligations for insurance intermediaries.<\/p>\n\n\n\n<p>Its relevance lies primarily in explaining why the RIS places strong emphasis on acting in the client\u2019s best interest, on suitability requirements and on clear, comparable disclosures, particularly in contrast to unregulated online content.<\/p>\n\n\n\n<p>For intermediaries, this element therefore has strategic and explanatory relevance only and does not constitute a remaining implementation concern. <\/p>\n\n\n\n<p>For Becobra members, the relevance of the RIS thus lies not only in its direct scope of application, but also in the regulatory context and supervisory trajectory set by the agreed framework.<\/p>\n\n\n\n<h4 class=\"wp-block-heading\"><strong><strong>4. What the political agreement settles<\/strong><\/strong><\/h4>\n\n\n\n<p>The political agreement on the Retail Investment Strategy settles a number of core concepts that structure the future regulatory framework for retail investment activities and their interaction with insurance distribution.<\/p>\n\n\n\n<p>In particular, the agreed RIS framework confirms and reframes, at a conceptual level:<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n<li><strong>inducements and remuneration<\/strong>, by excluding a general ban on commissions while introducing a reinforced best interest test governing how inducements may be received and justified;<\/li>\n\n\n\n<li><strong>value for money<\/strong>, as a guiding product\u2011governance principle, requiring that costs and charges be justified in light of product characteristics, benefits and performance, without introducing direct price regulation at Level\u202f1;<\/li>\n\n\n\n<li><strong>the investor journey<\/strong>, by strengthening consistency requirements between product design, information, advice and distribution;<\/li>\n\n\n\n<li><strong>suitability and appropriateness assessments<\/strong>, whose central role is reinforced for investment\u2011based products within the existing proportional and principle\u2011based IDD logic;<\/li>\n\n\n\n<li><strong>transparency and disclosure obligations,<\/strong> notably through revisions to the PRIIPs Key Information Document (KID), aimed at improving comparability, readability and usability for retail investors.<\/li>\n<\/ul>\n\n\n\n<p>The political debate on whether these concepts should form part of the RIS framework is therefore closed. What remains lies in their interpretation and implementation, rather than in the scope or objectives of the agreement.<\/p>\n\n\n\n<p>The agreement also confirms that the RIS does not introduce new provisions on third\u2011country intermediaries. While this issue was discussed during the legislative process, it was ultimately kept outside the scope of the RIS framework and deferred to any future review under existing legislation.<\/p>\n\n\n\n<h4 class=\"wp-block-heading\"><strong><strong>5. Key issues to keep in mind in the implementation phase<\/strong><\/strong><\/h4>\n\n\n\n<p>The issues below should be read in light of the agreed RIS framework. They highlight areas where particular attention will be required in respect of final legislative wording, during national transposition and supervisory implementation, rather than open negotiation.<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n<li>I<strong>nducements, best interest and supervisory interpretation: <\/strong>While the agreement rules out a general ban on commissions, the revised best interest test will play a central role in assessing whether inducements are compatible with client protection objectives. How this test is interpreted and applied by supervisors will be decisive in practice, particularly as regards proportionality, documentation and justification.<\/li>\n\n\n\n<li><strong>Value for money and product governance: <\/strong>The agreed framework places strong emphasis on value\u2011for\u2011money considerations in product design and distribution. While the Level\u202f1 text avoids hard price controls, value\u2011for\u2011money assessments may significantly influence supervisory expectations. Ensuring proportional application across different products and business models will therefore be a key challenge in implementation.<\/li>\n\n\n\n<li>P<strong>reserving scope discipline: <\/strong>Although the agreed RIS framework is focused on retail investment products, its amendments are embedded within the IDD, which applies across the insurance market. This creates a residual risk that retail\u2011oriented concepts could be extended, through interpretation or supervisory practice, to non\u2011life or commercial insurance distribution. Maintaining a clear regulatory boundary between retail investor protection and broader insurance intermediation therefore remains a key implementation and supervisory issue, even after the political agreement.<\/li>\n\n\n\n<li><strong>Suitability, investor journey and proportionality: <\/strong>The reinforcement of suitability requirements goes hand in hand with increased attention to the overall investor journey. Experience shows that such concepts may influence broader supervisory practice beyond their formal scope. Preserving proportionality and respect for different intermediary business models will be essential during implementation.<\/li>\n\n\n\n<li><strong>PRIIPs KID and information overload: <\/strong>Revisions to the PRIIPs KID aim to improve comparability and understanding for retail investors. At the same time, there is a risk of renewed information overload if layered or digital disclosures are not implemented in a user\u2011centric manner. Ensuring usability and consistency across information channels will be a key implementation challenge.<\/li>\n<\/ul>\n\n\n\n<h4 class=\"wp-block-heading\"><strong>6. Conclusi<\/strong>on<\/h4>\n\n\n\n<p>The Retail Investment Strategy has now reached a mature stage, with its core political choices settled and a clear procedural path towards application.<\/p>\n\n\n\n<p>While it does not introduce immediate operational obligations for insurance intermediaries, the RIS reshapes fundamental conduct\u2011of\u2011business concepts \u2013 notably around inducements, value for money, suitability, the investor journey and disclosures \u2013 which will influence future supervisory expectations across insurance distribution.<\/p>\n\n\n\n<p>For Becobra members, the RIS should therefore be understood as a context\u2011setting and forward\u2011looking framework. Becobra will continue to monitor its implementation closely and inform members as developments become concretely relevant.<\/p>\n\n\n\n<h4 class=\"wp-block-heading\"><strong>Disclaimer<\/strong><\/h4>\n\n\n\n<p>This document is provided for information purposes only. It does not constitute legal advice and may evolve as the European legislative process progresses.<\/p>\n","protected":false},"excerpt":{"rendered":"<p>In early April 2026, it was confirmed that the interinstitutional technical discussions on the Retail Investment Strategy (RIS) have been concluded, following the political agreement reached at the end of 2025. The texts are now entering the final lawyer\u2011linguist review phase, ahead of formal adoption and publication. Becobra therefore publishes an updated analysis &#8211; below [&hellip;]<\/p>\n","protected":false},"author":3,"featured_media":7363,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[44,50],"tags":[83,91],"rol":[81],"class_list":["post-9536","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-legal-affairs-and-compliance","category-systems-and-operations","tag-private","tag-slotje","rol-standaard-lid"],"acf":[],"_links":{"self":[{"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/posts\/9536","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/comments?post=9536"}],"version-history":[{"count":3,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/posts\/9536\/revisions"}],"predecessor-version":[{"id":9547,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/posts\/9536\/revisions\/9547"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/media\/7363"}],"wp:attachment":[{"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/media?parent=9536"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/categories?post=9536"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/tags?post=9536"},{"taxonomy":"rol","embeddable":true,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/rol?post=9536"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}