What is Product Disclosure Statement (PDS)?

A Product Disclosure Statement (PDS) is the headline disclosure document for retail offers under Part 3 of the FMCA. The form, content, and length of a PDS are tightly prescribed by the FMC Regulations 2014.

Structure (per FMC Regulations 2014 Schedule 4): 1. Key information summary — opens the document with target return, fees, risks, minimum. 2. Section 1 — Key information summary. 3. Section 2 — How does this investment work? 4. Section 3 — Description of the underlying investment portfolio. 5. Section 4 — What are the risks of investing? 6. Section 5 — What are the fees? 7. Section 6 — What taxes will you pay? 8. Section 7 — Who is involved? (manager, supervisor, custodian). 9. Section 8 — How to complain. 10. Section 9 — Where you can find more information. 11. Section 10 — How to apply.

Length: a managed investment scheme PDS is capped at approximately 12 pages in physical print equivalent. The intent is brevity — the long-form detail lives in the SIPO and the Other Material Information (OMI) documents.

Filing requirement: a PDS must be filed on the Disclose Register before the offer opens and re-filed when materially updated. A PDS that contains a misstatement or omission of a material matter is itself a regulatory breach.

Wholesale offers do NOT need a PDS — Schedule 1 of the FMCA exempts wholesale offers from Part 3 disclosure. Wholesale managers typically prepare an Information Memorandum (IM) instead, which is similar in structure but contains substantively wholesale-only language and is shared after the investor self-certifies under one of the seven Schedule 1 pathways.

PDS-vs-IM in practice: an investor moving from retail KiwiSaver to wholesale private credit experiences the transition: PDS available freely on a public website; IM only after demonstrating wholesale qualification. The substantive content is similar but the access controls are not.