CCI puts the pressure on Manufacturers and Distributors

The U.K.’s incoming Consumer Composite Investments (CCI) regime is going to shake up how product information is disclosed to retail investors.

During the Summer, Broadridge participated in a number of highly productive Financial Conduct Authority (FCA) workshops on the CCI, including one which looked at how its proposals could transform the relationships between manufacturers, distributors and investors.

CCI: A brief recap

Under the CCI, the final contents of which are expected to be published later in 2025, the PRIIPs KIDⁱ and UCITS KIIDⁱⁱ, will both be replaced with a Product Summary Document (PSD).

This is part of a wider post-Brexit remit under the Financial Services and Markets Act 2023 to repeal and replace EU financial services law with rules designed specifically for the UK.

Amidst concerns that the PRIIPs KID and UCITS KIID are not that easy for investors to navigate, the FCA has instructed the PSD be technology neutral, outcomes focused, adopt standardisation only when necessary, and enable consumers to access the right information at the right time. Any document being distributed to prospective retail investors also needs to be simple, concise, easy to use - both physically and digitally, and formatted so that it allows people to accurately benchmark and visualise the relationship(s) between returns, costs and risk.

All of this is designed to improve the quality and succinctness of the product information being provided to retail investors. This serves everyone’s interests. For regulators, investors need to be protected and the best way to ensure this is to give them as many details as possible about the costs, risks and performance of the products they are acquiring. At the same time, fund managers and distributors recognise that prospective buyers will not purchase investment products if they do not have enough information about them.

If implemented well, the CCI could help stimulate retail investment in the UK.

Manufacturers and Distributors digest the impact of the CCI

The CCI imposes a number of new requirements on manufacturers and distributors.

Under the rules, manufacturers must supply a PSD to distributors, with the core information, e.g. the CCI’s name, its objectives, costs and charges, risk and performance metrics, provided in a machine-readable data file. On receipt, distributors must then pass the document downstream to end investors, both before the sale of a fund, and afterwards.

However, the FCA has given distributors a degree of flexibility in terms of how they use the data contained within the PSD – in other words, distributors have scope to make adjustments to the document if they see fit. The regulator argues this wriggle room could allow a distributor to improve on the manufacturer’s PSD - and may help achieve better outcomes for investors. This is based on the assumption that distributors will have a deeper understanding than manufacturers about who the target market actually is, along with their bespoke information requirements.

Although the rules permit distributors to develop their own PSDs, in doing so, they are wholly responsible for ensuring the contents are “clear, fair and not misleading”ⁱⁱⁱ.

Even though distributors have the ability to amend a manufacturers PSD under the CCI regime, a lot of distributors do not want to change the PSDs many view the PSD as something which they should just passively host and nothing more. Also, some distributors would argue that they already offer engaging investor tools, raising further doubts about the merits of letting them refine or edit PSDs.

Meanwhile, smaller distributors have highlighted they do not have the bandwidth or resources to make these sorts of amendments to PSDs.

"As the CCI reshapes product disclosure, both manufacturers and distributors face a balancing act between innovation and compliance."

Stephen Johnston

Head of Broadridge Fund Communication Solutions

Manufacturers are somewhat alarmed that distributors – should they choose to – have autonomy to revise their PSDs. Imagine a scenario whereby Distributor A makes a few additions to the PSD, Distributor B keeps it as it is, and Distributor C removes some of the contents.

Whilst the majority of manufacturers are incredibly diligent about monitoring the information that distributors send out about their products, this flexibility which the CCI affords will require manufacturers to double down on their oversight of distributors, creating yet more work at a time when the industry is already grappling with rising costs and regulations.

Next steps for manufacturers and distributors

Despite its good intentions, the CCI’s PSD provisions are causing some confusion for manufacturers and distributors alike.

It is clear manufacturers and distributors require clarification from the FCA on what their responsibilities are, and this is something which Broadridge is looking to facilitate through its industry engagement efforts

Plan now for a timely, smooth transition. The rules are still in flux, but it’s not too early to speak to an experienced partner who can help you understand and prepare for changes as they unfold.

Frequently Asked Questions

The CCI is a forthcoming UK regulatory framework to improve how investment product information is disclosed to retail investors. It will replace the current PRIIPs KID and UCITS KIID documents with a new Product Summary Document (PSD) focused on clarity, technology neutrality, and investor outcomes.

Under the new regime, manufacturers must create PSDs containing core product data—such as objectives, costs, risks, and performance—in a machine-readable format. Distributors must share these documents with investors both before and after sale. The rules also give distributors limited flexibility to adapt PSDs for their clients’ needs—though they remain responsible for ensuring all information is clear, fair, and not misleading.

Manufacturers are concerned that allowing distributors to amend PSDs could lead to inconsistent versions of the same document being shared with investors, undermining comparability and confusing the market. Meanwhile, many distributors—especially smaller firms—say they lack the resources to edit PSDs and would prefer simply to host the manufacturer’s original version.

Manufacturers and distributors should begin reviewing their disclosure processes, data-sharing systems, and oversight arrangements to ensure they can comply once the CCI takes effect. Ongoing engagement with the Financial Conduct Authority (FCA) and industry groups, such as those facilitated by Broadridge, will be critical to clarify roles, responsibilities, and implementation expectations.

^{i Packaged Retail and Insurance-based Investment Products Key Information Document}
^{ii Undertakings for Collective Investment in Transferable Securities Key Investor Information Document}
^{iii CP24/30: A new product information framework for Consumer Composite Investments | FCA}