--- title: "ESMA Q&A 1821 — Q&A — Post-sale reporting [Answer Published]" shortTitle: "ESMA Q&A 1821 — Q&A — Post-sale reporting [Answer Published]" answer_id: ESMA_QA_1821 topic: "Information to clients on costs and charges" status: "Answer Published" type: qa instrument_type: qa authority: ESMA binding: false binding_character: non_binding legal_status: in_force regulation: "MiFID II" mifid_level3: true mica_level2: false legal_basis: "MiFID II" date: 6 June 2017 source_link: https://www.esma.europa.eu/publications-data/questions-answers/1821 lifecycle: "Answer Published" text_version: "ESMA Q&A register, 6 June 2017" source_url: "https://www.esma.europa.eu/publications-data/questions-answers/1821" check_status: matched verified: true last_checked: 2026-10-26 checked_against: "the ESMA publication" source: prepared_by: "ESMA" published_by: "ESMA" published_in: "ESMA Q&A tool" evidence: prepared_by: "ESMA Answer" locator: "ESMA Q&A entry ESMA_QA_1821: field 'ESMA Answer', no 'Answer provided by' line" document_type: "qa_answer" legal_nature: "not_legislation" addressees: "not stated in the document" dates: published_on: "2017-06-06" question_submitted_on: "2017-06-06" locators: published_on: "ESMA Q&A Excel export ESMA_QA_1821, column 'Esma responses', date line" question_submitted_on: "ESMA Q&A Excel export ESMA_QA_1821, column 'Date of submission'" lifecycle_label: "Answer Published" --- **Answer by ESMA, published in its Q&A tool · not legislation · published 6 Jun 2017 [Answer Published]** *Answer Published · ESMA Q&A register, 6 June 2017 · Checked against the ESMA publication on 26 Oct 2026 · [Official source](https://www.esma.europa.eu/publications-data/questions-answers/1821)* | | | |---|---| | **Full title** | ESMA Q&A 1821 — Q&A — Post-sale reporting \[Answer Published\] | | **Prepared by** | ESMA | | **Published by** | ESMA, in the ESMA Q&A tool | | **Reference** | ESMA_QA_1821 | | **Document type** | Q&A | | **Legal nature** | Not legislation | | **Addressees** | Not stated in the document | | **Dates** | Published 6 June 2017; question submitted 6 June 2017 | | **Legal basis** | MiFID II | | **Related instruments** | None recorded | | **Text on this page** | Word for word — the full text of the ESMA publication | **Post-sale reporting** ### Question What steps should an investment firm take when calculating the costs of products that fall within the PRIIPS transition period, like UCITS during the 3 January 2018 to 31 December 2019 period? *** ### Answer \[ESMA 35-43-349 MiFID II Q&AS on Investor protection Ch. 9, question 10\] UCITS do not have to provide a PRIIPs KID until 31 December 2019 and until that moment are only obliged to comply with the requirement to provide a Key Investor Document under the UCITS IV directive (2009/65/65). Based on Article 32(2) of the PRIIPs Regulation, and depending on the Member State, this exemption can apply to other non-UCITS funds (e.g. AIFs). While the UCITS KIID provides information on the costs and charges of UCITS (or non-UCITS, when applicable) with regard to ongoing charges (e.g. management fees), one-off charges (e.g. entry and exit charges) and incidental charges (e.g. performance fees), not all costs items are included therein. For instance, the UCITS KIID does not include information on the transaction costs a UCITS incurs when trading. An investment firm should however disclose all costs, including all costs of the financial instruments. Therefore, where for instance the information on transaction costs, which would be expected to be calculated using the methodology referred to in the PRIIPs RTS, is not publicly available the investment firm would be expected to liaise with the UCITS manager (and, where applicable, the manager of a non-UCITS fund) to obtain it. During this transition period, transaction costs might be assessed by using the method provided for in paragraphs 21 to 23 of Annex VI of the PRIIPs RTS. *** **Source:** [ESMA original document](https://www.esma.europa.eu/publications-data/questions-answers/1821)