Preparing for CCI disclosures: Practical steps for asset managers

This podcast episode is based on the Deloitte Luxembourg article below and includes content generated, assisted, or edited using artificial intelligence technology. It has been reviewed by a human prior to publication. The voices featured are synthetic. This podcast is provided for general information purposes only and does not constitute any kind of professional advice rendered by Deloitte Luxembourg. Deloitte Luxembourg accepts no liability for any loss or damage whatsoever sustained by any person who uses or relies on the content of this podcast. 

Introduction

When the Financial Conduct Authority’s (FCA) Consumer Composite Investments (CCI) regime comes into force, asset managers will need to fundamentally rethink how they communicate costs, risks, and performance to UK retail investors. The new framework marks a deliberate shift away from prescriptive disclosure templates, giving firms greater flexibility and responsibility to produce disclosures that are transparent, accessible, and genuinely client centric.

Preparing for the transition will require more than a regulatory repapering exercise. Firms must strengthen the quality and governance of underlying data, modernize operating models, and align cross-functional teams across product, legal, operations, and technology. Success will depend on the ability to source reliable data, streamline disclosure workflows, and translate technical product information into language that investors can readily understand.

Drawing on recent implementation experience, four priority areas are emerging as critical for asset managers seeking to deliver an effective and scalable response to the CCI regime.

Information architecture: Scope, strategy, and design

The starting point for any CCI program is to establish a clear and comprehensive scope. Firms must identify every product and share class accessible to UK retail investors, irrespective of fund domicile or distribution structure. In practice, firms must determine their preferred disclosure template strategy early. While standardized industry templates can accelerate implementation and support regulatory consistency, many asset managers are pursuing hybrid approaches that combine core market standards with tailored branding, investor messaging, and firm-specific disclaimers. This allows firms to balance implementation efficiency with a more differentiated and client-focused disclosure experience.

This design phase is also where governance and customer experience begin to intersect. Firms must carefully balance visual identity and marketing considerations alongside mandatory regulatory content, ensuring disclosures remain both compliant and accessible. Product and marketing teams, working closely with compliance and legal, should agree early on how key information such as costs and charges will be presented, whether through itemized breakdowns, layered summaries, or simplified explanatory text aligned to consumer duty expectations.

Mastering data: Performance, costs, and methodologies

Firms should reassess operational processes to align with the CCI regime’s new cost and performance methodologies. Attempting to adapt existing frameworks without fully evaluating the revised requirements is likely to create compliance and control gaps. For ongoing charges, operations teams will need to apply more robust look-through calculations, capturing even smaller allocations to underlying target funds that may previously have fallen outside reporting thresholds.

The new regime also raises the bar for historical data management. Firms will need to source and reconcile past performance data across multiple systems, as performance reporting will require the consolidation of up to 10 years of historical data. Where benchmarks or investment strategies have changed during that period, firms should be prepared to provide clear visual explanations that help investors interpret performance in the right context.

Bridging the clarity gap: Plain language and approvals

Firms should adapt their drafting and review processes to meet the consumer duty’s heightened expectations around readability and investor understanding. The FCA’s emphasis on plain and intelligible language—often aligned to an eighth-grade reading level—represents a significant shift for legal and compliance teams more accustomed to drafting technical prospectus language.

AI tools can support this transition by helping translate complex investment concepts into clearer retail-facing language. However, firms will still need robust governance around content production and review. Legal, product, and marketing teams should align early on a shared plain-language glossary, establish clear ownership of disclosure content, and define formal sign-off responsibilities. Structuring these reviews in sequence prevents bottlenecks before publication.

In practice, sequencing these reviews effectively will be critical. A structured drafting and approval process can help firms maintain consistency, reduce rework, and avoid publication bottlenecks as disclosure volumes increase ahead of implementation.

Technology integration and operating models

Finally, firms should establish the technical infrastructure required to produce, distribute, and maintain CCI disclosures at scale. A key decision for IT and digital teams will be whether disclosures are delivered through dynamic hosted JSON feeds or through static PDF documents. While PDF-based approaches may offer a faster path to implementation, JSON integration provides greater long-term flexibility by enabling automated data refreshes and more efficient distribution across platforms and third-party portals.

Delivering this capability sustainably will require a clearly defined Target Operating Model (TOM). Producing a CCI disclosure is inherently cross-functional, requiring coordinated from operations, risk, portfolio analytics, IT, and compliance teams. Firms should therefore define clear ownership across the disclosure lifecycle — from calculating ongoing charges and maintaining 10-year performance datasets to updating static product information and overseeing publication controls.

Establishing clear accountability will be essential. Assigning a single owner as the final approval and governance lead can help firms strengthen post-publication oversight, accelerate remediation where updates are required, and ensure disclosures remain accurate as underlying data, market conditions, and product characteristics evolve.

Next steps for CCI readiness

Preparing for the CCI regime will require asset managers to move quickly from regulatory interpretation to operational execution. Firms should begin by establishing clear ownership across data, legal, compliance, product, and marketing functions, ensuring accountability is embedded throughout the disclosure lifecycle.

Early priorities should include auditing historical performance datasets, validating cost calculation methodologies, and simplifying disclosure language to align with consumer duty expectations. Firms that address these foundational operational and governance challenges early will be better positioned to build scalable and reliable reporting processes ahead of implementation.

More broadly, the transition to CCI should not be viewed solely as a compliance exercise. The regime presents an opportunity for firms to modernize disclosure frameworks, strengthen investor communication, and demonstrate greater transparency in how products, risks, and costs are presented to retail clients.