Consumer Composite Investment (CCI) FAQ

The FCA have published their Policy Statement (PS25/20) for their new retail disclosure framework, the Consumer Composite Investment (CCI) regime.

Below you’ll find an essential update: the new CCI regulations have been released, and understanding their key details, timelines, and required next steps is critical to maintaining compliance and staying ahead of change. If you have any follow-up questions or would like to arrange a call with us on the topic, please do reach out.

A CCI is any one of the below products:

  • Open Ended Funds e.g. Unit Trusts, OEICs, UCITS, AIFs
  • Closed Ended Funds e.g. Investment Trusts
  • Other complex products e.g. Derivatives
  • IBIPs
  • CFDs
  • Structured deposits/products

Any firm that manufactures or distributes a CCI to retail investors in the UK.

UCITS KIID and PRIIPs KID presale disclosures are being replaced by the CCI Product Summary Document (“PSD”). Please see the sections below detailing a summary of changes.

Format: 

  • Non-prescriptive ‘Product Summary Document’ (“PSD”) i.e. no page limitation and no structured template.
  • Provide durable medium to retail investor before and after sale of product.
  • FCA “expect firms to use plain English rather than technical jargon”.

Costs:

  • Ongoing Costs as a headline figure (per UCITS model) – no longer combining one off costs and ongoing costs
  • One-off Costs to be prominently displayed.
  • Implicit Transaction costs removed.
  • Explicit Transaction costs do not need to be aggregated with ongoing costs but should be disclosed, but not necessarily in costs section
  • Performance Fee  a narrative description only.
  • Look-through to underlying funds is required, excluding underlying closed-ended investment funds.
  • No ‘reduction in yield’ methodology applied (PRIIPs methodology).

Risk Info:

  • Move to a 1-10 scale using UCITS standard deviation methodology based on 10 years of data.
  • Provisions have been made for a risk score that bounces between two buckets but does not reflect a material change in volatility.
  • Adding +1 to illiquid product risk scores as opposed to auto assigning a ‘9’.
  • Ability to -1 to a risk score where 90% or more capital protection.

Performance:

  • Graph type changed to be a linear graph.
  • Monthly data points to be used instead of Annual data points. This is a change from the consultations which noted “quarterly” data points were to be used.
  • Pre-merger performance requirement removed.

Filing:

  • Product Summary Document to be filed with FCA.


Refresh frequency:

  • Minimum Annually.

Over the next 18 months, Manufacturers must transition to the new regime, in which they will be required to produce a ‘Product Summary’ document and provide the ‘core information’ in a machine readable format (like EMT/EPT .csv format). This will allow distributors to present the information on their platforms. Manufacturers will have the option to adopt the rules early subject to distributor readiness.

We expect FinDatEx to announce an update to their Data Templates in the near future to support CCI specific fields, thereby enabling manufacturers to continue to produce one EMT/EPT for both UK and EU markets.

There is a 14 month transition period for all CCIs, starting on 6th April 2026 and running until 8th June 2027. This represents an 18 month implementation timeline from today.

  • 08 Dec 2025: Policy Statement and Final rules announced by the FCA
  • 19 Feb 2026: Filing Deadline for UK UCITS KIID refresh
  • 06 Apr 2026: Legislation commences (earliest implementation)
  • 31 Dec 2026: Expiry of UCITS Exemption in UK
  • 08 Jun 2027: Deadline for CCIs to move into the new regime

Additional Info

We have an on-demand webinar “Consumer Composite Investments Explained: What the FCA’s New Regime Means for You” which was held in early January 2026. Our expert panel, featuring speakers from the FCA and Hargreaves Lansdown, dove into the nuances of the new regime, and unpacked how the FCA’s principles based, focused approach marks a step change from prescriptive disclosure templates under PRIIPs and UCITS.

Stephen Johnston, head of Fund Communications Solutions at Broadridge, has said in the Financial Times that “the FCA proposals are an important step towards smarter retail disclosures which result in better outcomes for investors. Greater flexibility means firms must make informed, defensible decisions about how to apply these principles in practice. But ultimately, this flexibility should enable disclosures that are more comprehensible, engaging and informative.”

For more information on the CCI regime, please visit our dedicated CCI Homepage which we hope you find useful.

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