Introduction

In an effort to improve the client experience, the United Kingdom will begin transitioning from the UCITS Key Investor Information Document (KIID) and PRIIPs Key Information Document (KID) frameworks to the new Consumer Composite Investments (CCI) regime. This significant development puts forward a more flexible and proportionate product information framework that will apply to firms manufacturing or distributing consumer composite investments (CCIs) to retail investors in the UK.

Final rules for the CCI framework are expected later in 2025, with an 18-month transition period leading to an effective date around mid-2027, at which point the UCITS KIID will cease to exist in the UK. 

The move represents a philosophical shift in retail investment disclosure. For fund managers distributing into the Crown Dependencies of Jersey, Guernsey, and the Isle of Man, this raises a critical question: What next?

Without any formal statement to date, we have considered the global market practice, benefits of alignment, and the Crown Dependencies’ current regulatory objectives to get a sense of what’s ahead.

Global context of market practice

The market practice of financial services sector in the Crown Dependencies has long been to align with global standards, particularly those of its primary partner, the UK. While not a formal legal requirement, it has been a pragmatic commercial standard adopted to reduce friction and maintain a strong international reputation.

Consider the UCITS framework, a globally recognized platform with funds sold in over 90 countries. Preliminary research into various mutual fund prospectuses confirms that leading global asset managers have indeed adopted a standardized approach for these jurisdictions, explicitly stating they provide UCITS KIIDs to non-EEA investors.

Incentive for alignment

The financial ecosystems of the Crown Dependencies are deeply intertwined with the UK's, creating a powerful incentive to align with UK financial regulation. Regulatory divergence could risk UK banks withdrawing services, undermining the islands' reputations and damaging their status as well-regulated financial centers closely tied to the UK market. 

The new CCI framework, guided by the UK's Consumer Duty, also aligns with the islands' own strategic goals of upholding international standards and protecting consumers.
 

Regulatory precedent and priorities

As the UK’s final rules are still under consultation, regulators in Jersey, Guernsey, and the Isle of Man have not yet made public statements on adopting the CCI framework. However, this should not be seen as opposition. It only requires consulting the regulators' existing strategic priorities to get a sense of their direction:

• The Jersey Financial Services Commission (JFSC) is focused on "futureproofing" Jersey's competitive position. 
• The Guernsey Financial Services Commission (GFSC) is a "committed participant" in international discussions and emphasizes disclosure over rigid prescription. 
• The Isle of Man Financial Services Authority (IOMFSA) has a statutory objective to implement recognized international standards and already has a "Recognised Scheme" regime that accepts home-jurisdiction documents from the UK.

These consistent patterns of strategic alignment are the strongest indicators of a future market practice that aligns with CCI.

A clear path forward

The most logical outcome is that the Crown Dependencies will align with the UK’s choice of disclosure for funds already distributed in the UK, resorting to EU PRIIPs only where no CCI is available. This approach serves both as a commercial necessity, driven by the interdependence of the UK and Crown Dependency financial ecosystems, as well as a practical necessity to avoid duplication. Adopting a single disclosure document for both the UK and the islands would promote more efficiency and consistency for fund managers, preventing a fragmented "third way" that could undermine the islands' reputation for simplicity and alignment.

This transition is not a simply a new obligation to comply with CCI, but an opportunity to modernize investor communications—and enhance the islands' positioning—in a post-KIID world.