CCI final rules: How to operationalize new risk and data standards

At a glance

The new rules published on 8 December 2025 by the FCA replace the previous UCITS/PRIIPS KI(I)D documents in use in the UK with flexible summaries, and firms must implement updated risk and data standards by June 2027 to remain compliant.

A closer look

For nearly a decade, UK retail investments have been governed by the UCITS or PRIIPs regulation. The FCA’s PS25/20: Supporting informed decision-making confirms the transition to the new Consumer Composite Information (CCI) framework, replacing PRIIPs KIDs and UCITS KIIDs.

The final rules mark a clear shift toward an outcome-focused, consumer duty-aligned approach. Manufacturers will move from automated template production to a model requiring active governance and judgment.
 

The "Hybrid" model: Flexible presentation, standardised data

The CCI regime combines flexible communication with strict data requirements:

Product summary

Manufacturers have discretion over the design and layout but it must:

• Be titled "Product Summary,"
• Be strictly separate from marketing materials, and
• Provide a reasonable and sufficient standalone understanding of the product.

Core information disclosures (the data layer)

Underlying data on costs, risk, and performance must be delivered as structured, machine-readable files (e.g., CSV) for distributor use.

Digital-first delivery

Distributors may highlight key metrics digitally, provided the full, unamended product summary is delivered in a durable medium at or shortly after sale.
 

Costs and charges: Addressing industry concerns

The FCA has restructured disclosures of cost and fees.

• Four cost buckets: One-off entry costs, one-off exit costs, ongoing costs cost figures (OCF), and transaction cost, each shown as percentage and in pound sterling figures.
• Performance fees/carried interests: Must be clearly explained and show potential fees on a illustrative example.
• Transaction costs: Include only explicit costs (e.g., broker commissions, exchange fees, taxes, and legal costs); implicit costs are excluded.
• Investment companies: Where funds invest in closed-ended vehicles, the ongoing cost of investee closed-ended funds (CEIFs) must appear as a separate, prominent line item.
   

Risk and performance: From calculation to judgment

The new regime refines how risk and return are communicated, reintroducing the role of manufacturer discretion.

• Risk Scale (1–10): Based on 10-year volatility.
• Judgment gateway: Manufacturers must assess whether the calculated score reflects true risk.
• Upgrade if volatility understates risk (e.g., illiquid assets).
• Cautious downgrade permitted with clear justification in the Product Summary.
• Performance: Past performance must be shown via a line graph net of costs and based on a hypothetical investment once sufficient history exists.
   

Mandatory distributor responsibilities

Distributors must:

Delivery of the product summary

Provide the manufacturer’s official, unamended product summary in a durable medium at or shortly after sale.

Highlighting minimum information

The distributor is obligated to ensure that, during the pre-sale process, the consumers are clearly shown:

• The product explanation.
• Ongoing and other costs.
• Risk/return score and warnings.

Use and validate data

Use the machine-readable Core Information Disclosures and “act on concerns” if data appears misleading or outdated; they may need to pause distribution.

Comply with consumer duty

Ensure that the entire communication process is fair, clear, and not misleading.
 

Implementation timeline

• 6 April 2026 – Legislation commences: The "optional transition" period begins. Firms may begin switching to the new CCI Product Summary.
• 8 June 2027 – Implementation deadline: The regime comes fully into force. All legacy disclosure documents (UCITS KIIDs/PRIIPs KIDs) for UK retail investors must be withdrawn and replaced by CCI Product Summaries.
• Update requirements: Manufacturers must review the core information and product summary at least annually, with out-of-cycle updates for material change (e.g., strategy, cost, risk profile).
   

Conclusion

PS25/20 provides the definitive rules for the UK’s new disclosure regime. CCI offers a major opportunity to improve how value and risk are communicated but demands stronger data governance and more active oversight. With legislation beginning in 2026, firms should start designing “core information” data models and Product Summary templates now. 

How Deloitte can help 

To meet the June 2027 deadline, Deloitte provides targeted support to help you translate the new CCI rules into compliant and efficient operations:

• Product summary design and compliance: We offer strategic design guidance and conduct compliance reviews to ensure your flexible Product Summary meets disclosure requirements and aligns with Consumer Duty expectations.
• Risk governance frameworks: We design governance processes to support the new judgment-based risk scoring, helping you implement and evidence defensible upgrades or adjustments to the 1–10 risk score.
• Cost model transformation: We help remodel cost systems to apply the four required cost buckets accurately and correctly separate and present CEIF costs, improving transparency and regulatory compliance.