What must a UCITS publish for investors, and by when?
The prospectus, annual and half-yearly reports and quarterly statements with their deadlines, what the prospectus and annual report contain, how NAV is calculated and published, the KIID and the PRIIPs KID, and the rules on marketing communications.
By the ExamPass CY editorial teamLast reviewed 8 min read
Short answer
The management company or VCIC supplies CySEC and every point of sale with each fund's prospectus, annual report and half-yearly report. The annual report is due within 4 months of the year end, the half-yearly within 2 months. Quarterly statements are due within 15 days, or 2 months for the fourth quarter, which adds the year's profit and loss account. Prospectus changes reach CySEC 15 days before use. NAV is calculated at least once a fortnight. A KIID is given free before subscription; since 1 January 2023 a PRIIPs KID satisfies that duty.
Investor information at a glance
| Document or duty | Rule |
|---|---|
| Annual report | Within 4 months of the year end; audited, with the full auditor's report and remuneration disclosures |
| Half-yearly report | Within 2 months of the end of the first six months; prepared under IAS 34 |
| Quarterly statements | Assets and expenses within 15 days for the first three quarters; the fourth adds the year's profit and loss account and distribution, within 2 months |
| Prospectus changes | Sent to CySEC no later than 15 days before investors get the new version |
| Financial year | The calendar year; the first one ends on 31 December of the year operations begin |
| Language | Greek, Greek and English, or English only if the licence file was in English; one set of documents for an umbrella fund |
| Before subscribing | KIID and fund rules free of charge; prospectus and latest reports only if requested |
| NAV calculation | First working day of each calendar fortnight, or more often; every working day for money market and exchange-traded UCITS |
| NAV publication | On the management company's website, on the second working day after each valuation date |
| Marketing statement | No guaranteed return, and past performance does not guarantee future returns |
Source: Law 78(I)/2012, Articles 16(4), 55–60, 62–65A and 66(4), as amended by Laws 88(I)/2015, 52(I)/2016, 134(I)/2021 and 154(I)/2022; Regulation (EU) 2019/1156, Article 4.
In the exam
The exam is written from the exam material, which predates the changes below. Expect its answer. If that answer is not among the options and the current rule is, choose the current rule.
NAV publication day
Exam material: NAV and dealing prices are published on the business day after each calculation, including the daily figures for tradable units.
Current law (since 15 June 2012 (Law 78(I)/2012, Article 60(1)); fortnightly calculation and website publication since 16 June 2015 (Law 88(I)/2015)): They appear on the management company's website on the second working day after each valuation date; money market and exchange-traded UCITS calculate every working day.
Umbrella fund documents
Exam material: An umbrella UCITS provides its prospectus, reports and statements separately for each compartment.
Current law (since 15 June 2012 (Law 78(I)/2012, Article 55(6))): One prospectus and one set of reports and statements cover all its compartments.
KIID and PRIIPs KID
Exam material: Before subscribing, investors receive the KIID free of charge; no other key document is mentioned.
Current law (since 1 January 2023 (Law 154(I)/2022, after the PRIIPs exemption for UCITS ended under Regulation (EU) 2021/2259)): UCITS sold to retail investors produce a PRIIPs key information document, which the Law treats as meeting the KIID rules.
Questions on what a KIID must contain still follow the KIID rules, which remain in the Law.
Which documents are required, and when?
For each common fund it manages, the management company, and each VCIC, prepares a prospectus, an annual report and a report on the first half of each financial year, files them with CySEC and makes them available at all points of sale. It also prepares a summary statement of assets and expenses at the end of each quarter. Deadlines run from the end of the period: 4 months for the annual report, 2 months for the half-yearly report, 15 days for each of the first three quarterly statements, and 2 months for the fourth, which also carries the year's profit and loss account and distribution of profits. The financial year is the calendar year, and the first one ends on 31 December of the year the fund starts operating.
Documents are in Greek, in Greek and English, or in English alone where the licensing file was in English only. The exam material says an umbrella fund produces these documents for each compartment; since 2012 the Law has required one prospectus and one set of reports covering all compartments.
The prospectus gives what investors need for an informed judgement, including a clear account of the fund's risks, and is kept up to date. It says whether the fund may use derivatives for efficient portfolio management, in particular hedging, or as investments. It warns prominently where the fund invests mainly in assets other than transferable securities and money market instruments, or tracks an index, and where NAV is likely to be highly volatile. It includes the remuneration policy or a summary with a website link and a free paper copy. The management company is liable for losses caused by false, misleading or missing information. On request, investors may also obtain the fund's quantitative risk limits, its risk management methods and recent trends in the main risks and yields.
The annual report contains the balance sheet or statement of assets and liabilities, an income and expenditure account, an activity report for the year and audited accounts with the full auditor's report. It also discloses total staff remuneration split into fixed and variable pay with the number of beneficiaries, totals by staff category, how pay is calculated, the results of policy reviews and material policy changes. Reports are free on request, on paper if asked. Before subscribing, an investor must receive the KIID and the fund rules free of charge; the prospectus and latest reports are supplied only on request.
Terms used in this note
- KIID
- Key investor information document: the short standard summary of a UCITS given before subscription.
- PRIIPs KID
- The key information document under Regulation (EU) No 1286/2014, used for retail UCITS since 1 January 2023.
- Umbrella fund
- A UCITS with several compartments, each with its own portfolio, covered by a single prospectus.
What must the KIID and marketing communications say?
The key investor information document is labelled as such, short, non-technical and in Greek and/or English. It must be fair, clear, not misleading and consistent with the prospectus. It identifies the fund and its regulator and covers objectives and investment policy, the risk and reward profile, costs and charges, and past performance or performance scenarios. It says where to find more information, that civil liability arises only if the document is misleading, inaccurate or inconsistent with the prospectus, and where the remuneration policy is available. For an exchange-traded fund, ESMA guidelines add the 'UCITS ETF' label and require the prospectus, KIID and marketing to explain the portfolio transparency policy and where portfolio details and the indicative NAV are published; the prospectus also explains how the indicative NAV is calculated.
The exam material describes only the KIID. Since 1 January 2023, when the PRIIPs exemption for UCITS expired, UCITS sold to retail investors have produced a PRIIPs key information document, and Article 65A of the Law, added by Law 154(I)/2022, treats it as meeting the KIID rules. Compare What must clients be told about financial instruments and about costs and charges?
Any advertisement or document inviting subscription, online included, must state clearly that returns on UCITS units are not guaranteed and that past performance does not guarantee future returns; a guaranteed UCITS gives only the second part. Since 2 August 2021, Article 4 of Regulation (EU) 2019/1156 has set the general standards. Marketing communications must be identifiable as such, present risks and rewards equally prominently, and be fair, clear and not misleading. They must not contradict the prospectus or KIID, and must say where, how and in which language those documents can be obtained.
How to think about it
Build the calendar from the longest deadline down: annual report 4 months, half-yearly 2 months, fourth-quarter statement 2 months, other quarterly statements 15 days, prospectus changes 15 days before use. Then separate what investors must be given before investing (the KIID and the rules) from what they can simply ask for (prospectus and reports).
Common mistakes
Mixing up the deadlines. The 15-day deadline applies to the first three quarterly statements and to prospectus filings; the fourth-quarter statement and the half-yearly report get 2 months.
Assuming everything is handed over before investing. Only the KIID and fund rules are compulsory; the prospectus and reports are supplied on request.
Expecting a prospectus per compartment. One prospectus and one set of reports cover the whole umbrella.
Treating the KIID as today's retail document. Since 1 January 2023 retail UCITS use the PRIIPs KID, which the Law accepts in place of the KIID.
Legal references
- The Open-Ended Undertakings for Collective Investment Law of 2012 (Law 78(I)/2012), consolidated Greek text on CyLaw (amendments up to Law 10(I)/2025) (opens in a new tab)
Article 16(4) (documents before subscription) · Article 55 (documents and deadlines) · Article 56 (prospectus) · Article 57 (financial year) · Article 58 (reports) · Article 59 (availability) · Article 60 (NAV) · Articles 62–65 (KIID) · Article 65A (PRIIPs KID) · Article 66(4) (marketing statement)
- Law 154(I)/2022 amending Law 78(I)/2012 (PRIIPs KID), Official Gazette of 7 October 2022 (opens in a new tab)
New Article 65A, in force 1 January 2023
- Regulation (EU) 2021/2259 extending the PRIIPs transitional exemption for UCITS (opens in a new tab)
Exemption ended on 31 December 2022
- Regulation (EU) 2019/1156 on cross-border distribution of collective investment undertakings (opens in a new tab)
Article 4 (marketing communications, applicable from 2 August 2021)
- ESMA Guidelines on ETFs and other UCITS issues (ESMA/2014/937), as hosted by CySEC (opens in a new tab)
Paragraphs 15–18 (identifier, portfolio transparency and indicative NAV disclosures)
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