Banking and Finance Newsletter | New prior notification regime for PRIIP advertising

The Banking and Finance Department at SRS Legal has published a newsletter dedicated to the new prior notification regime for the marketing of PRIIPs, introduced by Decree-Law No. 134/2026 of 9 July, which replaces the previous prior approval model with a prior notification regime allowing for objections by the competent authorities.

Key changes include the adoption of a more proportionate and efficient supervisory model, the setting of a 10-working-day deadline for any objections to advertising, and the exclusion of certain non-complex collective investment undertakings from this regime.

The legislation also introduces changes to the prior notification regime for the Key Information Document (KID), sets out transitional rules for pending procedures and reinforces advertisers’ responsibility for ensuring the compliance of advertising, thereby promoting a more streamlined regulatory framework without compromising the supervisory powers of the competent authorities.