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FCA’s new CCI Rules: Navigating the shift from UCITS and PRIIPs

Survey results

Following the FCA’s final rules on the Consumer Composite Information (CCI) framework published in December 2025, fund managers must now move from UCITS and PRIIPs disclosures to a new, outcome-focused regime. CCI final rules: How to operationalize new risk and data standards

The transition period runs from April 6 2026 to 8 June 2027. To support planning for this change, we have published a detailed analysis and market survey:  

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Our survey of 15 global asset managers highlights a challenging implementation landscape:

  • Mobilisation gap: 54% of firms have not yet started implementation, suggesting that for many market participants, CCI efforts may not commence until well after the transition period opens in April 2026.
  • Design tension: While 56% of firms prioritize simplification and PRIIPs-alignment, 25% % intend to leverage the new flexibility to strengthen their brand and enhance the investor experience.
  • Operational hurdles: The three most frequently cited challenges are template design (58%), budget constraints (50%), and distributor integration (50%).
     

Strategic implications

The CCI framework introduces a hybrid model that separates flexible product summaries from a structured core data layer. It also shifts risk assessment from purely formulaic approach to judgement-based scoring, requiring firms to establish new governance frameworks.

How Deloitte can help

Deloitte can assist you in translating these rules into action through:

Producing CCI product summaries from April 2026, leveraging your existing EU KID datasets.

Compiling the new 1–10 risk scale and associated cost measures to ensure alignment with the CCI framework.

Delivering machine-readable data layers to support distributor integration, while actively progressing toward alignment with emerging CCI market templates and standards.

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