Amendments to the PRIIPs Legal Framework 

Decree-Law No. 134/2026 of 9 July was published today, introducing significant amendments to the regime governing advertising and the prior notification of the key information document relating to packaged retail investment and insurance-based investment products (“PRIIPs“), the legal framework of which is set out in Annex II to Law No. 35/2018 of 20 July.

 Among the amendments introduced by the decree-law, we highlight the following:

• The mandatory prior approval regime is replaced by a prior notification regime to the competent authority, which has 10 working days to raise an objection (previously, the authority had 7 working days to grant approval). Advertising is no longer subject to a six-month validity period, and the obligation of periodic renewal is repealed;
• The new prior notification regime does not apply to collective investment undertakings that qualify as non-complex financial instruments;
• The competent authorities may now extend, by regulation, the advance notice period for the prior notification of the key information document up to a maximum of five working days.

The decree-law will enter into force on 14 July 2026. Prior approval procedures for advertising pending on the date of entry into force of the decree-law shall continue to be governed by the previous regime. 

For more information, please contact rvr@ccsllegal.com

[Photo by: Gabrielle Henderson, available at unsplash.com]