[ESMA 34-43-392 UCITS Q&A, Section 1, 1a]

No: except where a UCITS is subject to national laws and regulations in its home Member State that require updates to be made by 18 March 2016, the UCITS will be allowed to update the KIID with this information at the next annual update after 18 March 2016, or on the first occasion after 18 March 2016 on which the KIID is revised or replaced for another purpose, if the information is available at that point in time. Similarly, a UCITS will be allowed to add the relevant information to the prospectus at the next occasion it is revised for another purpose or in any event by 18 March 2017 at the latest. 

In the meantime, UCITS management companies should make available on a relevant website the additional information about the management company’s remuneration arrangements as soon as it becomes available.