A lighter onboarding process, decision-useful disclosures and effective use of digital tools will be key to success, says EFAMA.
Persistent barriers—such as limited financial literacy, information overload, and complex onboarding procedures—continue to prevent EU citizens from moving their savings out of low-yielding bank deposits and into long-term investment solutions. EFAMA urges policymakers to deliver a more intuitive, engaging, and accessible client experience, particularly for first-time investors.
The European Fund and Asset Management Association (EFAMA) has submitted its response to ESMA’s Call for Evidence on the Retail Investor Journey, providing recommendations for how to simplify the investment process to better serve Europe’s savers.
Key EFAMA recommendations include:
- Extending the suitability-light regime to both commission- and fee-based advice, particularly for retail-ready products like UCITS and retail AIFs.
- Assessing suitability at the portfolio level rather than product-by-product, to better reflect real-world investment practices and allow advisers to tailor strategies that optimise outcomes across risk tolerance, investment horizon, and investment objectives.
- Cutting through information overload: Regulatory disclosures are currently overwhelming and overly technical. EFAMA recommends a shift toward layered, user-friendly formats, allowing retail clients to access key information in a more digestible format. Investors should have the option to dive deeper if they wish, but quality and clarity should take precedence over quantity.
- Balancing opportunity and risk in disclosures: Disclosures should emphasise key benefits like diversification, wealth creation over time, hedge against inflation and other qualitative features that drive investment decisions. An over-emphasis on risk may discourage rather than encourage potential investors.
- Harnessing digital tools alongside enhanced financial literacy: Digital tools have the potential to streamline and personalise the investor experience. However, this must complement – not replace – human advice and robust financial education. Accessible, quality advice remains essential to ensuring that digital engagement translates into sound, long-term investment outcomes.
- No need for new tests and additional bureaucracy: EFAMA cautions against introducing duplicative new tests such as the "best interest" test, which risk complicating the investment process without delivering real benefits to end-investors. The Retail Investment Strategy’s focus should remain on improving existing rules—not adding new layers of bureaucracy.
- Simplifying the PRIIPs KID: The current PRIIPs KID is rarely read or understood by retail investors and often fails to deliver its intended value. EFAMA firmly opposes costly and burdensome overhauls but advocates for targeted, high-impact improvements. These include removing performance scenarios in favour of past performance and eliminating implicit transaction cost disclosures. The goal should be a more intuitive, relevant document that genuinely helps investors make informed decisions.
EFAMA remains committed to building a regulatory framework that truly empowers retail investors, while supporting open and competitive EU capital markets.
Kimon Argyropoulos, Regulatory Policy Advisor at EFAMA, commented: “This is a key moment to rework the customer journey with a genuinely investor-centric approach. The current process is simply too complex and time-consuming. It discourages individuals from taking meaningful steps toward achieving their financial goals. If we want to build a strong investment culture in Europe, we need to empower individuals to understand their options, access the right products, and make informed decisions with confidence.”
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Notes to Editors
Read our leaflet on simplifying the Retail Investment Strategy here.
For further information, please contact:
Hayley McEwen
Head of communications and membership development
