WorkflowProduct Development & Fund Governance

PRIIPs KID Production

Every PRIIPs KID, in every language, proven against the fund data before it can publish

Every figure in every language proven against the fund data before a KID can publish.

See one case, screen by screen ↓
demo4,212versionsin one reissue — 612 share classes in 23 languages for 27 markets, each read back by the agents
demo1,736numbersread back across 28 versions of one share class; the one that disagreed blocked release
target0versionsreleased with a figure that disagrees with the master or the fund data
target11business daysto reissue 4,212 versions, from the fund data file to signature
In short

What is PRIIPs KID Production?

PRIIPs KID Production drafts and checks the PRIIPs KID, the key information document, for every share class in the language of every market where it is sold, and drafts the UK CCI Product Summary from the same data. Each KID is built from the fund data template, translated and back-translated, and every figure in every language, from the summary risk indicator and performance scenarios to the cost disclosure, is proven against the master before release. Manufacturers must publish a KID for each packaged product sold to retail investors in the EU, and for every UCITS share class since January 1, 2023. A named reviewer approves each language and the Head of Product Compliance signs each share class.

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Updated

The problem

Why a PRIIPs KID reissue takes weeks, and still lets a wrong figure through

Every PRIIPs KID has to say the same thing in every language. A share class sold to retail investors in the EU needs a key information document in the language of each market where it is registered, and UCITS have needed one since January 1, 2023. Quillfield Capital's European range runs to 612 share classes in 27 markets: 4,212 live documents, reissued after every fee, risk or prospectus change and at least every 12 months. The figures come from the fund administrator's European PRIIPs Template (EPT) file, a template engine builds the English, translators and a language vendor produce the rest, and a few reviewers spot-check a sample of PDFs.

The risk sits in the pages nobody reads back. Translation memory carries last February's transaction costs into this year's sentence. A vendor's post-edit swaps two digits, so the Polish version prints ongoing costs of 1,12% while the master says 1.21%. A locale breaks the thousands separator, or a risk indicator is copied from last year's version. The data was checked going in; the document going out was not. An inaccurate KID is a breach: member states must allow fines of at least €5 million or 3% of turnover, an investor who relied on it can claim damages, and distributors delist a share class whose document is missing or out of date.

typical€5Mor 3% of turnover, at least: the fine member states must allow for an inaccurate KID
typical12monthsthe longest a KID may go without review — sooner after any significant change
Where a reissue's business days goestimated
By hand25 days
With the solution11 days
  • Loading the data template file and chasing missing records2 → 0.5 d
  • Drafting the English masters, per share class3 → 0.5 d
  • Translation and the language vendor's post-edit6 → 3 d
  • Language review and checking the figures8 → 5 d
  • Fixing mismatches and re-checking the versions3 → 1 d
  • Compliance sign-off and publication to every channel3 → 1 d

Estimated split for a full reissue of a range this size, by hand and with the solution. With the solution the agents read every version back; people review, approve and sign.

How it works

How a share class becomes 28 checked KIDs

Eight agents draft, translate, back-check and prove every figure; a reviewer per language approves and compliance signs.

What comes in
Data in612 share classes, 27 markets · data template, prospectus, NAVs, costs, registrations
Agents at work
Drafting agentEnglish master
Then
Translation agent23 languages
Back-translation checkermeaning
Then
Numeric consistency agentevery figure
Risk and scenario agentsecond opinion
Then
Release agentpublish and verify
A person decides
Language reviewer and complianceapprove each language, sign
What comes out
Every figure proven
Published to every channel
Evidence per version
One case, step by step

One PRIIPs KID in 28 versions, from the data template to signed

Quillfield Global Funds SICAV's prospectus update takes effect on Monday, November 2: ongoing costs fall for 31 sub-funds after the September 24 fee review, and every document carries a new complaints address. All 4,212 versions are reissued for publication on Friday, October 30. Here is Monday, October 19, screen by screen, in the working solution.

  1. 01Monday, 8:40 a.m.

    The cycle clock, and five things that need her

    Nadia Okafor · KID Production Manager

    Nadia's home shows the reissue on one line, from the prospectus approved on October 9 to the effective date, with 9 business days left to publication. 3,212 of 4,212 versions are signed and scheduled, 47 are blocked by a mismatch, 388 are in language review (12 past the 2-day service level) and 6 risk second opinions disagree with the calculation provider. Each item under “Needs you” has one next step: see the mismatch, regenerate 18, nudge reviewers, open fund data, retry the Nordic portal.

    Overnight, the Numeric consistency agent: “Read 4,212 rendered versions back and checked every figure against its master and the data template. 47 mismatches in 47 share classes.”

  2. 02October 13–14

    Every figure in the master is pinned to its data row

    Drafting agent

    Jonas Weber accepted the fund administrator's EPT v2.1 file at 6:05 p.m. on October 13: 612 records, 598 complete. The next day the Drafting agent built 598 English masters and held 14 for incomplete records. For Euro High Yield, Class A EUR Acc, the record explorer shows each field beside the previous KID: row 118, ongoing costs, now 1.21% against 1.30% before the fee review. The master's 22 key figures each point to their row, and it fits on three sides of A4.

    “The fund data template (EPT v2.1) from the fund administrator: one record per share class, every figure in a KID comes from a row here.”

  3. 03One decision

    18 stale figures fixed by cause, not one by one

    Nadia Okafor and the Numeric consistency agent

    Checks groups the 47 mismatches by cause: stale figure 18, number format 11, transposed digits 9, meaning drift 5, risk indicator 4. In 18 versions the transaction-cost sentence still matches the February 2026 KID, because translation memory offered the old sentence. Nadia regenerates all 18 in one step, and the run shows itself: the plan, the sentence rebuilt from row 121, each language rewritten with its locked phrases, 18 pages re-rendered and read back — 18 of 18 match.

    “Handed to 6 reviewers for approval · nothing publishes until each approves.”

  4. 04The wall

    28 language versions on one screen — 27 of 28 match

    Nadia Okafor · KID Production Manager

    Quillfield Euro High Yield UCITS, Class A EUR Acc (LU2471836598) opens as a wall of its 28 versions in 23 languages. Each page carries its key figures in the market's own format: SRI 3, ongoing costs “1,21 %”, the moderate scenario at four years “11.520 €” in Germany and “11'520 €” in Switzerland. One tile is red. The release gate across the top reads 27 of 28, release blocked, and the Sign share class button stays locked.

    Back-translation checker: “Back-translated all 27: 1,107 sentence pairs, every one above the 0.92 meaning threshold (lowest 0.94, Finnish). The Polish cost sentence means what the master means; only its number differs.”

  5. 05She asks

    “Why is Polish blocked?” — answered with its sources

    Numeric consistency agent

    Nadia asks the agents beside the wall. The Polish version prints ongoing costs of 1,12%; the master and the data template say 1.21%. The amount beside it, 117 EUR, still matches 1.21%, so the percentage is the error: two digits transposed in the language vendor's post-edit, job TR-88412. The other 61 numbers match. Each claim links to row 118, the master page and the Polish page.

  6. 06Side by side

    The English master, the Polish as printed, and the Polish back in English

    Translation agent and Back-translation checker

    The compare view lines up every sentence: the English master, the Polish as printed and a translation back to English on a second model, each number tagged with its data row. The checks strip reads numbers 61 of 62, meaning 41 of 41 sentences at or above 0.92, locked phrases 12 of 12, three sides of A4, paying agent and complaints text present. The Translation agent adds that its own draft of October 14 read 1,21% and proposes setting the figure back. Nadia cannot approve it.

    “Language approvals belong to the Polish reviewer.”

  7. 079:12 a.m.

    The Polish reviewer approves the correction

    Marta Zielińska · Translation reviewer, Polish

    Marta reviews the Polish versions for 146 share classes a cycle. She sees the one line that changes — 1,12% to 1,21% wartości Twojej inwestycji rocznie — with EPT row 118, master page 2 and the vendor's post-edit as its sources. She approves with reason code L2, Approved after correction, and signs through single sign-on.

    “Matches the master and EPT row 118. The agent re-checks the whole version after you approve.”

  8. 08Seconds later

    62 of 62 numbers re-checked, and the wall turns green

    Numeric consistency agent

    The correction is applied on page 2, the Polish PDF is re-rendered on three sides of A4, all 62 numbers are read back against the master and row 118, the meaning is re-checked at 0.98, and the wall updates: 28 of 28 versions match. Marta's decision, its reason code and her signature are on the record.

  9. 09Signed

    Compliance signs only what has been proven

    Robert Hale · Head of Product Compliance

    With every version matched, the Sign share class button opens for Robert. The sign-off shows what he is signing: 28 of 28 versions match the master, 28 approved by their language reviewers, 1,736 numbers proven against the data template. He signs with S1, All versions match and reviewed. The Release agent schedules the share class for Friday, October 30, 6:00 a.m. CET, to six channels, from the fund documents site and distributor portals to the UK feed and the archive.

    “Signing does not let you edit content.”

  10. 10A second opinion

    The risk indicator recomputed — and a person decides

    Risk and scenario agent

    The Risk and scenario agent recomputed the risk indicator, scenarios and costs for all 612 share classes from NAV history and cost data: 606 agree with the calculation provider. For Emerging Markets Local Debt, Class A EUR Acc, it finds a VaR-equivalent volatility of 12.3% against 11.8% supplied, because the provider used weekly returns for January 2022 when nine daily NAVs were missing. That crosses the 12% line from risk class 3 to 4; accepting class 4 would reissue 41 versions across both of its share classes. Claire Fontaine, product governance, decides.

    “Product governance decides; the agent never overrides the provider.”

Who it’s for

Built for everyone who signs off a KID.

The same reissue, seen by five of the people who carry it — what the cycle looked like, and what it looks like now.

NO
Nadia OkaforKID Production Manager, London · runs every reissue
KID Production Manager
Before
Runs every cycle — data in, masters, translations, reviews, release — and hears from a distributor when a document is wrong. “I can't read 4,212 PDFs. Show me the ones that are wrong.”
Now
Opens the 47 versions that disagree, grouped by cause, fixes a cause in one decision and asks the agents why any tile is red.
MZ
Marta ZielińskaLanguage review panel · Polish versions for 146 share classes
Translation reviewer, Polish
Before
Reads whole Polish PDFs to find the line that matters. “Give me the line, the English and the number's source.”
Now
Sees the Polish line beside the English master, the back-translation and the data row, and approves, edits or rejects with a reason code.
RH
Robert HaleHead of Product Compliance, London · signs each share class
Head of Product Compliance
Before
Signs share classes on the strength of a sample. “I sign only what has been proven.”
Now
Signs a share class once every version matches and every reviewer has approved, with the count of numbers proven in front of him.
CF
Claire FontaineProduct governance · Quillfield Asset Management (Luxembourg) S.A.
Product Governance Officer
Before
Owns the 12-month review and every risk-class change. “If the risk class moves, I want to know why before the document does.”
Now
Sees the recomputed volatility and the working behind it, decides the risk class with a reason code, and approves each reissue plan before the agents act.
JW
Jonas WeberFund data analyst, Luxembourg · owns the EPT feed
Fund data analyst
Before
Finds out a field was missing when a document is already late. “When a field is missing, tell me which class and who owes it.”
Now
Sees the file validated on arrival, the 14 incomplete records by field, and sends one request to the fund administrator.
Built on the engine

8 agents. Each with one job, and hard limits.

Eight agents draft, translate, back-check and prove every figure; a reviewer per language approves and compliance signs.

Drafting agent

Builds each English master KID from the EPT record, the product master and the prospectus, and checks it against the template and three sides of A4.

  • Never invents or rounds a figure — every figure comes from an EPT row
  • Holds a share class whose data template record is incomplete
Translation agent

Writes each market version from the master with the approved term base, locked regulatory phrases and the market's mandatory text, and routes it to the language vendor where policy requires a human post-edit.

  • Never changes a number
  • Never edits an approved version
Back-translation checker

Translates every version back to English on a second model from a different provider and compares the meaning with the master, sentence by sentence.

  • Never edits — it flags drift with the sentence pair
  • A sentence below the 0.92 meaning threshold goes to the language's reviewer
Numeric consistency agent

Reads every rendered version, extracts every number, normalizes the market's number format and proves each figure against the master and its EPT row; it runs the release gate.

  • Never clears its own flag and never releases
  • Hands flags below 90% confidence to a person — two Romanian number-format flags at 78% went to the Romanian reviewer
Risk and scenario agent

Recomputes the VaR-equivalent volatility, market risk class, performance scenarios and costs over time from NAV history and cost data, and runs the Article 15(2) checks.

  • Never overrides the calculation provider's figure
  • Every disagreement goes to product governance
UK summary agent

Drafts the UK Product Summary and the Core Information file from the same data, and explains each difference from the EU KID.

  • Never publishes
  • Approval as a financial promotion is a person's
Change monitor

Watches prospectus updates, board fee resolutions, EPT differences, new registrations and the 12-month clock, and proposes a reissue plan with a reason for every version.

  • Never starts a reissue without product governance approval
Release agent

Schedules and publishes signed share classes to the fund documents site, distributor portals, data vendors and feeds, verifies every published file's fingerprint and retries failures.

  • Publishes only signed share classes
  • Never with an open mismatch
Language reviewers and Head of Product Compliance

Approve, sign. The agents propose; a named person decides.

Ask in plain words

Ask about any share class, language or figure

Ask in plain words, or tell the agents what to do. Every answer is cited, and the decision stays with a person.

Why is Euro High Yield, Class A EUR Acc blocked?

The Polish version prints ongoing costs of 1,12%; the master and the data template say 1.21% (row 118). The amount beside it, 117 EUR, still matches 1.21%, so two digits were transposed in the language vendor's post-edit (TR-88412). Marta Zielińska decides.

Which versions still show last February's transaction costs?

18 versions in 6 languages: German 4, French 3, Italian 3, Spanish 3, Dutch 3 and Swedish 2. Translation memory carried the February sentence; the data template has the October figure (row 121). The production manager can regenerate all 18 from Checks.

Is the Emerging Markets Local Debt risk class changing?

Possibly. The recomputed VaR-equivalent volatility is 12.3% against 11.8% supplied; 12% is the line between class 3 and 4 (Annex II). Claire Fontaine decides.

What is left before the October 30 release?

3,212 of 4,212 versions are signed and scheduled. 392 wait for compliance sign-off, 388 are in language review (12 overdue), 47 are blocked by a mismatch, 96 are being re-translated and 77 wait for data.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

TodayThe KID production manager's home: the reissue clock to publication, versions signed, blocked and in language review, what needs her and what the agents did overnight.
Fund data template recordsThe European PRIIPs Template (EPT) record for one share class, field by field against the previous KID, with the source of every figure.
Mismatches by cause47 mismatches grouped by cause, and 18 stale transaction-cost figures regenerated in one run, read back and handed to their reviewers.
PRIIPs KID language versionsOne share class's PRIIPs KID in 28 language versions, each with its risk indicator, costs and moderate scenario in the market's number format, and the release gate.
Ask the agentsA question beside the wall — why is the Polish version blocked? — answered with the data row, the master page and the vendor job.
KID translation check, side by sideThe English master, the Polish version as printed and its back-translation on a second model, sentence by sentence, with every number pinned to its data row.
The reviewer decidesThe Polish reviewer approves the agent's correction with a reason code and her signature.
Re-checked after approvalThe correction applied, the Polish PDF re-rendered, 62 of 62 numbers read back and the meaning re-checked: 28 of 28 versions match.
Compliance sign-offThe Head of Product Compliance signs the share class once every version matches: 28 approved, 1,736 numbers proven against the data template.
Summary risk indicator second opinionThe summary risk indicator recomputed from NAV history for 612 share classes, the six that disagree with the provider, and the working behind each.
UK CCI Product SummaryThe UK Product Summary drafted from the same data as the EU KID — a risk and return score of 4 of 10, the ongoing charge in pounds — with each difference explained.
Audit trailEvery action by people and agents with who, what, when, why and the evidence, on a verified hash chain, and an evidence pack to export.
Rules and thresholdsNumeric tolerance, meaning threshold, agent confidence, length, risk recompute tolerance, the moderate scenario check and locked phrases per language.
Governance

Built for disclosure risk: proven, approved, on the record.

Every figure cited to its data rowEach number in every version points to its row in the European PRIIPs Template record and to the master. Every agent statement shows its sources and how sure it is.
No release with an open mismatchThe release gate blocks a share class while any version disagrees with the master. Sign share class stays locked until every version matches — 27 of 28 is not enough.
A named reviewer for every languageEach language version is approved, edited or rejected by its own reviewer, with a reason code. Reviewers act only on their own languages; the production manager cannot approve a language or sign.
Compliance signs each share classThe Head of Product Compliance signs each share class and approves UK Product Summaries as financial promotions. Product governance approves reissue plans, risk-class changes, and rule and model changes.
Agents never approve their own workAgents prepare, check and propose. They never approve, sign, release or clear their own flags; a flag a person overturns needs a reason code and a note, and is counted in the cycle report.
An audit trail that cannot be rewrittenEvery action by people and agents is recorded with who, what, when, why and the evidence, on a hash chain the solution verifies — this morning at 8:30 a.m., with no break. Evidence packs export per version, share class or cycle, and records are kept 10 years after a version is superseded.
Configuration

Your KID procedure, as settings

The thresholds every version is checked against are versioned settings: the administrator proposes a change, product governance approves it, and the agents are re-evaluated before it applies.

SettingDefaultChoose from
Numeric tolerance0Every figure must equal the master after the locale's number format is applied
Meaning threshold0.92Back-translation similarity per sentence; below it, the language's reviewer decides
Agent confidence90%Below this, the agent hands the item to a person
Length3 sides of A4Every version
Risk recompute tolerance± 0.3 pointsVolatility difference, or any change of risk class
Moderate scenario check5 pointsMean return moved since the last KID
Vendor post-edit9 marketsMarkets where a human linguist edits the agent's draft
Language review service level2 business daysEscalation after 1 day overdue; flagged lines shown first
Connections

Works with the systems a KID program already runs on

Fund data template feedthe fund administrator's EPT v2.1 file, one record per share class
Product master and registration matrixshare classes, markets, paying agents
Fund accounting and cost data10 years of daily NAVs, ongoing charges and trades from the order management system
Translation management systemlanguage vendor jobs, translation memory and the term base
Document managementprospectuses, board fee resolutions and published KIDs
Publication channelsthe fund documents site, 12 distributor platforms and banks, the fund data distribution network
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
0
versions released with a figure that disagrees with the master or the fund data
Todaya sample of PDFs read
With agentsevery page read back
target
100%
of numbers in every language version proven against the data template
4,212 versions
612 share classes, 23 languages
target
11business days
to reissue 4,212 versions, from the fund data file to signature
By handweeks of turnaround
With agents11 business days

“demo” = seen in the working solution, on its sample fund range · “target” = the design goal, to be measured in a pilot · “estimated” = our estimate · “typical” = published rules (Regulation (EU) No 1286/2014, Articles 5, 7, 11 and 24 — fines of at least €5,000,000 or 3% of turnover; Delegated Regulation (EU) 2017/653, Article 15 — review at least every 12 months; FCA PS25/20, Consumer Composite Investments, December 8, 2025). Quillfield Capital and every fund, ISIN, vendor and person named on this page are fictional — characters and sample data in the working solution.

Questions

What product and compliance teams ask about PRIIPs KIDs.

What is PRIIPs KID Production?

PRIIPs KID Production drafts and checks the PRIIPs KID, the key information document, for every share class in the language of every market where it is sold, and drafts the UK CCI Product Summary from the same data. Each KID is built from the fund data template, translated and back-translated, and every figure in every language, from the summary risk indicator and performance scenarios to the cost disclosure, is proven against the master before release. Manufacturers must publish a KID for each packaged product sold to retail investors in the EU, and for every UCITS share class since January 1, 2023. A named reviewer approves each language and the Head of Product Compliance signs each share class.

What is the difference between a PRIIPs KID and a UCITS KIID?

In the EU, UCITS used the UCITS KIID until their exemption from PRIIPs ended on December 31, 2022; since January 1, 2023 they need a PRIIPs KID, with its 1 to 7 risk indicator, four performance scenarios and cost tables. In the UK, the UK PRIIPs KID and the UCITS KIID both give way to the CCI Product Summary by June 8, 2027.

How often must a PRIIPs KID be reviewed and reissued?

At least every 12 months, and whenever a change significantly affects it, including when the moderate scenario's mean return has moved by more than five percentage points (Delegated Regulation 2017/653, Article 15). The Change monitor reads prospectus updates, fee resolutions, EPT differences, new registrations and the 12-month clock, and proposes which versions to reissue and why. Product governance approves the plan before the agents act.

How does it check KID translations in every language?

Two ways. The Back-translation checker translates each version back to English on a second model and compares its meaning with the master sentence by sentence, against a 0.92 threshold. The Numeric consistency agent reads every rendered page, normalizes the market's number format and proves each figure against the master and its data row. A version that disagrees blocks the share class until its reviewer decides.

Does it recalculate the summary risk indicator and performance scenarios?

Yes, as a second opinion. The Risk and scenario agent recomputes the VaR-equivalent volatility, market risk class, scenarios and costs over time from NAV history and cost data, and runs the Article 15(2) checks. It never overrides the calculation provider: in the sample cycle 606 of 612 share classes agree, and the six that differ go to product governance with the working.

What replaces the PRIIPs KID in the UK, and can it produce the CCI Product Summary?

In the UK, the Consumer Composite Investments (CCI) Product Summary replaces the UK PRIIPs KID and the UCITS KIID: manufacturers may use it from April 6, 2026 and must from June 8, 2027. The UK summary agent drafts the Product Summary and the Core Information file from the same data as the EU KID: a risk and return score of 1 to 10 from 10 years of volatility, the ongoing charge as the headline in percent and pounds, and explicit transaction costs only. It explains why, for example, the UK score is 4 of 10 while the EU indicator is 3 of 7. Compliance approves it as a financial promotion.

Do people stay in control of what is published?

Yes. The agents draft, check and propose; they never approve, sign, publish or clear their own flags. Each language's reviewer approves it with a reason code, product governance decides risk-class changes and reissue plans, the Head of Product Compliance signs each share class, and nothing with an open mismatch can be signed or released.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — your KID procedure, your data template feed, your registration matrix and a sample of published KIDs — and it goes live once every quality gate has passed. We will walk you through it on your own share classes first.

See it on
your share classes.

We'll run PRIIPs KID Production on a sample of your own data template records and published KIDs.