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The prescription in Art 3(1) of the EU Regulation 583/2010 could not be clearer: "No other information or statements shall be included except where this Regulation states otherwise". The incorporation of the features described in the question therefore becomes a matter of interpretation; what do the other articles of the Regulation require and permit? Because the Regulation contains no mention of shareholder eligibility criteria, transaction and holding minima or the name of the investment manager or adviser, ALFI thinks that there are good grounds to suppose that they are not "essential" features of a fund, important though they are. ALFI therefore thinks that they are not required and would therefore not include them in the KID.
ESMA/2012/592 confirms that the name of the investment manager(s) of the UCITS should not be disclosed, but rather only the name of the UCITS management company. However, ALFI recognises that some practitioners might still consider at least the remaining features to be essential and therefore wants to know whether they are permitted and if so how to include them. In their case, ALFI thinks that the most plausible interpretation for permitting them is under Art 7(1) of the Regulation, where the word "including" suggests a non-exhaustive enumeration of the contents of that section of the KID, which contains similar information about redemption upon demand and a minimum holding period (Arts 7(1)(b) and 7(2)(f) respectively).
ALFI sees three reasons to be cautious about this: (1) regulators may consider that inclusion of additional information would create undesirable differences between supposedly standardised documents, which militate against the KID's purpose of greater transparency and comparability between products, (2) there may be no room in the KID to include such information without reducing it to "small print", and (3) ESMA/2012/592 explicitly rejects the disclosure of the name of the investment manager(s), whereas the disclosure of the name of the fund’s management company is based on Art 4(12) of the Regulation.