CCI: Implications for individual firms, the industry and investors

The Financial Conduct Authority’s new Consumer Composite Investments (CCI) regime represents a “step-change” in disclosure regulation that gives fund manufacturers new freedom to create innovative communication strategies aimed at helping consumers better understand financial products.

That’s the consensus of three expert panelists participating in a January 2026 Broadridge Webinar on CCI.

The FCA published its final CCI rules in December 2025. To help fund manufacturers and distributors assess the new rules and start planning strategies for implementation, Broadridge brought together industry and regulatory experts to discuss the goals, provisions, challenges and potential benefits of CCI.

The panelists agreed: The shift from the prescriptive mindset of the outgoing Packaged Retail and Insurance-based Investment Products (PRIIPs) regulation and Undertakings for Collective Investment in Transferable Securities (UCITS) KIID disclosures to the more flexible approach adopted in CCI has the potential to dramatically enhance disclosure policy and help build a stronger retail investment culture in the United Kingdom.

Comprehension over compliance

At the beginning of the Webinar, Ian Runacres, Technical Specialist in Consumer Investments Distribution Policy for the FCA, said flexibility sits at the heart of the new CCI rules. He explained that the FCA realised there were problems with PRIIPs and its Key Information Documents (KIDs), which he described as “dense, technical, and highly templated.” As a result of these shortcomings, “KIDs were not widely read, and among those that did read them, they were not widely understood,” he said.

Broadridge research backs this up. In 2025, Broadridge analyzed the language used in KIDs from 50 large UK asset managers. Of those documents, the vast majority were written at what would be considered an academic level. Only about 1 in 10 KIDs used language likely to be understood by the typical retail investor. Caoimhe Adams, Head of Regulatory Product at Broadridge, said these results suggest that UK disclosure had become “a case of compliance over comprehensibility.” That’s a missed opportunity for the industry, she said, since “clear language leads to an increased likelihood of someone investing.”

The new CCI regime is meant to change all that. By creating an outcome-focused framework that dictates standardisation only where absolutely necessary, the FCA is attempting to give manufacturers the flexibility to find new and creative ways to engage consumers and help them understand products and options. “We want to meet consumers where they are, not where a well-educated investor might ideally be,” Runacres said.

Simpler data, innovative approaches

Of course, the new disclosure rules do set some baseline minimum requirements for new Product Summary Documents (PSDs) in the areas of cost, risk and performance. But in all three topics, the FCA has consulted with industry to simplify and enhance data and it's presentation to make the information easier for retail investors to understand and use.

For costs, the new CCI format will strip out transaction costs and show headline ongoing costs represented in both percentage and monetary form, making it easier for retail investors to grasp how much will be charged and to compare costs with other investment alternatives.

For risk, the CCI will change from the prior seven-point scale to a new and more intuitive 10-point scale based on 10 years of data, up from the five-year data set used in UCITS. The new metric will be dubbed the Risk Return Score (RRS).

For performance, the CCI abandons past bar charts and tables based on quarterly performance data in favor of line graphs using monthly data. Line graphs should include relevant benchmarks for easy comparison. The CCI preserves accompanying narratives that explain performance, but the FCA has adjusted guidelines to prevent these sections from becoming overly focused on risk and instead present a better balance of risk and return.

Mark Walter, Head of Partnerships at Hargreaves Lansdown, said these changes will improve the quality of disclosures by making it easier for investors “to compare like with like.” However, he says the industry is most excited about the innovation the CCI will allow above and beyond these prescriptive elements.

What will that innovation look like? Manufacturers have wide leeway to experiment with ways to engage consumers. For example, a manufacturer might try to better contextualize costs by showing comparisons to the cost of funds in a similar peer group. On risk, a manufacturer might decide to illustrate the maximum drawdowns that have occurred over a five-year period to help put some context around the risk score. For performance, manufacturers might again turn to peer comparison as a useful gauge for potential investors.

Throughout the new disclosure documents, manufacturers are encouraged to use “nesting” techniques that allow investors to drill down for more detailed information on sustainability or any other topic.

Transitioning to a stronger retail investment culture

Firms are free to transition from KIDs and KIIDs to PSDs after April 6, 2026. However, conscious of the operational challenge the move poses to distributors, manufacturers, and data providers, the FCA has built in 14-month transitional period, with June 2027 as the final deadline for compliance.

To gauge industry plans and readiness, Broadridge conducted a survey of Webinar participants. The results show that a strong plurality—nearly 40%—plan to switch to CCI for year-end 2026. Firms seem to believe that it doesn’t make economic sense to proceed with another year under the old framework, but they need time to handle the operational challenges associated with the change.

The panelists agreed that the transition to CCI will impose significant costs and operational burdens on distributors, who must be prepared in advance to accommodate funds on their platforms, as well as on manufacturers and data providers. For that reason, they advise all parties to engage with industry trade bodies and partner closely with service providers to effectively manage the change.

Regardless of when individual firms adopt CCI, the data and discussion from the webinar made clear that the next year will mark a huge step in the FCA’s efforts to overhaul disclosure and build a stronger retail investment culture in the United Kingdom.