On 8 December 2025, the Financial Conduct Authority (‘FCA’) published PS25/20, setting out the final rules for the new Consumer Composite Investments (‘CCI’) regime, which will replace the existing PRIIPs Key Information Document (KID) and UCITS Key Investor Information Document (KIID) frameworks.

This reform marks one of the most significant overhauls of the UK retail investment disclosure regime in decades, introducing a single, UK‑specific disclosure framework for retail investment products.

The new regime is explicitly designed to support the FCA’s Consumer Duty and its wider objective of improving consumer outcomes while supporting market growth, moving away from rigid templates towards disclosures that genuinely help consumers make informed decisions. Instead of relying on prescriptive formats, firms will be expected to exercise judgement and demonstrate that disclosures are clear, meaningful and effective in supporting retail consumer understanding.

The regime comes into effect on 6 April 2026, with a final compliance deadline of 8 June 2027.

While the move away from the PRIIPs KID and UCITS KIID structure will be welcomed by many firms, the transition to the CCI regime introduces new operational, governance and disclosure challenges for firms manufacturing and distributing products to UK retail investors.

What are Consumer Composite Investments (CCIs)?

A CCI is broadly an investment product where returns depend on the performance of underlying or reference assets.

In scope (non‑exhaustive):

  • Open‑ended funds (e.g. UCITS, NURS).
  • Closed‑ended investment funds (e.g. investment trusts, VCTs).
  • Recognised overseas funds (including OFR funds).
  • Insurance‑based investment products (IBIPs).
  • Structured products and structured deposits.
  • CFDs and derivatives.
  • Debt securities with returns linked to indices or assets.

Out of scope (key exclusions):

  • Pension products.
  • Pure protection insurance.
  • Ordinary deposits (non‑structured).
  • Equity shares in commercial companies.
  • Plain‑vanilla listed corporate bonds.
  • Certain IBOR‑linked debt securities.

The scope of the CCI regime captures all products under the current UK PRIIPS regime, while also bringing additional investment products into scope, including UK UCITS, NURS, EU UCITS marketed under the Temporary Marketing Permissions Regime (TMPR) or Overseas Funds Regime (OFR), and UK-listed closed-ended funds (investment trusts).

Key changes under the CCI Regime

At the heart of the new regime is the Product Summary, which replaces the PRIIPs KID and UCITS KIID.

Manufacturers are given significant freedom over the design, layout and presentation of product summaries. The FCA has deliberately removed fixed templates and page limits, allowing firms to create disclosures tailored to their product and target market.

However, this flexibility comes with responsibility. Firms must be able to justify their design choices and demonstrate that disclosures meet Consumer Duty expectations and genuinely support consumer understanding and informed decision making.

How will it affect fund manufacturers and distributors?

  • Manufacturers are solely responsible for producing and maintaining the product summary.
  • Distributors must ensure an up‑to‑date product summary is available before selling a CCI to a retail investor.

The move away from the prescriptive format of the UCITS KIIDS and PRIIPS KIDs is a welcome development for many firms. However, the increased flexibility of the regime also presents its own problems.

Importantly, distributors are not required to present all information in the product summary pre‑sale. Instead, they should highlight the information consumers need to make a timely, informed decision, using judgment under the Consumer Duty.

Firms will need to exercise careful, considered judgment when designing the new Product Summaries to ensure they are compliant and remain useful to consumers.

What does the Product Summary need to contain and what is the format required?

While the format is flexible, certain information must be presented in a standardised and comparable manner, ensuring consumers can still compare products on a like‑for‑like basis where appropriate:

  • A brief explanation of the product and general information
  • Costs and charges information (as per Chapter 6 of the Product Disclosure Sourcebook in the FCA Handbook, (‘DISC’) requirements);
  • Risk and return information and scoring, with a brief explanation of the risk and return profile, including any required warnings;
  • Past performance information.

With regards to the presentation of costs and charges manufacturers will need to calculate costs and charges using the principles set out in DISC 6, including:

  • Using the applicable assumed investment amount which, for the most part, will be £10,000;
  • Covering costs and charges incurred over the previous 12 months; and
  • On a gross basis.

The Product Summary will revert to the more traditional presentation of past performance, and will no longer require the ‘performance scenarios’ previously prescribed under the PRIIPs KID regime.

Manufacturers must ensure all aspects of the Consumer Duty, particularly product governance rules, are incorporated into the Product Summary, which include identifying:

  • the target market of the CCI;
  • assessment of value of the CCI, including any relevant assumptions; and
  • any relevant risks, including those which may directly affect a consumer who identifies with vulnerable characteristics.

Firms may also choose to include additional information where this supports consumer understanding, providing the disclosures remain clear and proportionate.

CCI Implementation timeline: Key FCA deadlines

  • 6 April 2026: Legislation commences and an optional transition period begins.
  • From April 2026: Manufacturers may choose to adopt the new product summary or continue with existing disclosures.
  • 8 June 2027: The new CCI regime becomes fully mandatory.

The FCA has allowed an 18-month implementation period, giving firms time to redesign disclosures, update systems and embed appropriate governance and oversight processes.

Preparing for the CCI Regime: Next steps

For firms, success under the CCI regime will depend not just on compliance, but on how effectively disclosures support genuine consumer understanding and decision‑making.

Those firms that embrace the spirit of the regime – focusing on clarity, transparency and consumer outcomes – are likely to be best placed as the FCA continues its broader reform of the UK retail investment market.

By preparing early and developing both the format and data required for the Product Summary, firms can move forward with confidence and ensure ongoing compliance with both the CCI regime and the Consumer Duty.

How fscom can help

fscom supports fund manufacturers and distributors in interpreting and implementing new regulatory frameworks, including the transition from PRIIPs KIDs and UCITS KIIDs to the new CCI regime.

Our team can assist firms in assessing the impact of the new rules, designing compliant Product Summaries aligned with Consumer Duty expectations, and embedding appropriate governance and oversight across manufacturing and distribution processes.

If you would like to understand how the CCI regime may affect your products, disclosures, or operating model, our specialists would be happy to discuss how we can support your transition.

This post contains a general summary of advice and is not a complete or definitive statement of the law. Specific advice should be obtained where appropriate.