The FCA’s new Consumer Composite Investments (CCI) Regime – a hybrid approach to retail investment disclosures brings risks and opportunities

This blog has been updated following the FCA’s publication of final rules on its Consumer Composite Investments regime on 8 December 2025.

Who this blog is for

This blog is relevant for CROs, CCOs and all staff involved in managing regulatory disclosures, compliance, marketing and risk management at fund management and distribution firms as well as life insurers selling insurance-based investment products.

At a glance

• Earlier this week  the FCA published final rules on its new product information framework for Consumer Composite Investments (CCI regime: PS 25/20). This will replace the current rules under the Packaged Retail and Insurance-based Investment Products (PRIIPS), Undertakings for Collective Investment in Transferable Securities (UCITS), and non-UCITS retail schemes (NURS) regimes.
• The new regime aims to facilitate a simpler, less burdensome, and more flexible disclosures approach for firms. This will be a hybrid approach where specific core information and key metrics will be determined by prescriptive rules, but the overall design and delivery of disclosures will be guided by the Consumer Duty (the Duty).
• The overall shape of the new CCI regime has remained largely unchanged despite some amendments since the original consultation (CP 24/30). Key changes include:  scope clarifications, distributors will no longer be able to make changes to a manufacturer’s product summary (as previously proposed)  and a range of changes to disclosure of costs and charges and risk and return metrics (see the Appendix for more details).
• The new regime will require significant operational changes for manufacturers, increased information sharing across the distribution chain and the need for distributors to develop a communications and disclosures framework compliant with the Consumer Duty (the Duty).
• CCI will also introduce changes to prescribed technical metrics and require additional contextual narratives.  Firms may also be exposed to greater regulatory and conduct risk due to having to exercise judgement around what contextual and qualitative information to include alongside technical metrics.
• Firms should consider the new CCI regime alongside other key regulations and initiatives, including the Sustainable Disclosure Requirements (SDR), Targeted Support , Consumer Duty and clarifications around the role of distributors and manufacturers in distribution chains. The increased flexibility of the regime puts the onus on manufacturers and distributors who will have to assess the best way to disclose information. Firms will need to monitor customer understanding and review their approach to ensure the delivery of good outcomes.  Finally, firms able to improve customer understanding through high quality communications and disclosure are likely to be better positioned to benefit from the regulatory changes that will broaden access to investments for retail customers.
• The full CCI regime and rules will come into force on 8 June 2027. Manufacturers that wish to do so (including those of Overseas Funds Regime schemes) will be able to adopt the regime as early as 6 April 2026 (under the optional transitional period).

What has changed since the CCI consultation CP 24/30 ?

The overall shape of the new CCI regime has remained largely unchanged despite some key amendments since the original consultation (CP 24/30). The FCA’s final rules were informed by its extensive outreach with the IMW industry and consumer organisations – we have set out the key changes in the Appendix at the end of this article.

2. The new CCI regime – scope and timeline

The FCA has published its final rules on the Consumer Composite Investments Regime (CCI). The CCI will replace disclosure requirements under the on-shored PRIIPS    and UCITS regimes. The FCA’s objective is to create a simpler and more flexible regime that empowers consumers to make effective, timely and informed decisions and is fully aligned with the Duty.

Products in scope of CCI include open-ended funds, closed-ended funds, recognised funds, structured products, structured deposits, contracts for difference, insurance-based investment products, and other complex products such as derivatives. Note that this list is not exhaustive and as a first step firms should develop a process to determine whether existing or new products fall within the definition¹ of a CCI. Some specific exclusions include vanilla corporate bonds, pension products and pure protection insurance contracts.

The new regime will apply to any firm that manufactures or distributes CCI products to retail investors in the UK including firms not authorised by the FCA e.g. EU firms that distribute CCIs in the UK under the Overseas Fund Regime (OFR). To ensure consistency of consumer protection, the FCA is mandating that certain high-level product governance standards should apply to manufacturers who are not subject to the Duty when the firm is carrying on a CCI designated activity.      It also appears that FCA has dropped plans to provide specific Duty guidance for OFR firms as Treasury has taken the view that OFR funds operate in jurisdictions that have comparable consumer protection regimes. OFR funds will not be subject to the CCI regime. 

The full CCI regime and rules will come into force on 8 June 2027. Manufacturers that wish to do so (including those of Overseas Funds Regime schemes) will be able to adopt the regime as early as 6 April 2026 (under the optional transitional period).

2. A hybrid approach to disclosures: prescriptive rules underpinned by the Duty

The FCA expects the new regime to result in a simpler, less burdensome, and more flexible disclosures approach for firms. This will be a hybrid approach where specific core information and key metrics will be determined by prescriptive rules, but the overall design and delivery of disclosures will be guided by the Duty regime (see Figure 2).

Standardised rules will govern: the production of technical metrics (costs and charges, risk and return and performance metrics), a Product Summary document, and a machine-readable Core Information Disclosures document. The delivery of disclosures including narrative disclosures, templates, design, mediums and timing will be governed by the Duty rules and guidance.

3. What will change compared to current requirements? 

Table 1: Summary of proposed changes (source: CP 24/30 and updated for PS 25/20)

We expect the changes to result in increased operational and compliance costs to firms. The FCA expects that over a 10-year period the proposed changes would cost all firms £65.5m (the estimate was revised upwards from £48.8m in the original CBA). Firms may also be exposed to greater regulatory and conduct risk due to having to exercise judgement around what contextual and qualitative information to include.

Key actions and considerations for firms

Firms will have to think carefully about how to convey complex technical information in simple language. It will be crucial for firms to consider the Duty’s consumer understanding requirements and guidance and apply the associated guidance around layering  , relevance of information and using engaging language. They will also need to be able to evidence compliance with the Duty when implementing the new CCI regime. For example, key decisions about design and delivery of disclosures should be informed by outcomes monitoring.

For EU firms that manufacture funds distributed into the UK under the OFR, the new regime will now subject them to dual disclosure regulations. This may result in a significant compliance burden as they will need to continue to comply with the existing PRIIPs and UCITS regimes in the EU and with the CCI for funds marketed in the UK. Additional expertise and resources will be required to ensure they can meet dual disclosure requirements.

3.1 Information sharing and responsibilities across the distribution chain

The CCI requires manufacturers to produce a Product Summary alongside a Core Information Disclosures document and provide these to distributors. Distributors then have discretion to present additional information in innovative ways to end-investors but will no longer be able to amend the Product Summary.

Key actions and considerations for firms

Given that all distributors will receive a core information disclosure document with detailed information on the same funds, this will aid comparability between funds and potentially facilitate an improvement in fair value assessments. Both manufacturers and distributors should consider the impact of the new regime on their approach to fair value under the Duty.

Where technology is used to present core information in innovative ways e.g. where technical terms may have pop-up explanations, distributors should ensure that any such additional text is aligned with the manufacturers’ original messaging. Distributors will need to ensure that any innovative design of disclosures is compliant with the Duty. This will be a significant task for many distributors given that they currently have no discretion to amend the format of disclosures. To ensure that disclosure design is Duty-compliant, firms will need to create frameworks which take into account not only the format, timing and mediums of communication that lead to good customer outcomes, but also the governance and oversight required and a consideration of the regulatory risks that the firm will face.

Some distributors might choose to just pass on the Product Summary from the manufacturer to the customers (minimum disclosure). However, this approach should be underpinned by robust monitoring of consumer understanding to ensure the Product Summary and other disclosures are delivering good outcomes. This will clearly be an area where implementation will shed more light on the practical challenges and will require significant communication between manufacturers and distributors.

3.2 Changes to technical aspects of core information metrics

As per our “What’s Changed” box (appendix) and Table 1 above, the final rules contain changes to how the core information metrics are produced as compared to consultation CP 24/30 and PRIIPs respectively.

The FCA has confirmed following feedback that the OCF will still need to be disclosed as a headline figure, both as a percentage and as a pounds-and-pence number, but one-off costs and transaction costs should be excluded and disclosed separately.  Where CCIs have invested in other CCIs, costs will need to be pulled through into a synthetic OCF – where the CCI has invested in a CEIF, the CEIF’s costs will need to be presented separately in the Product Summary.

Regarding the 1-10 risk metric, the FCA has clarified it is a "risk and return score." While CCIs with illiquid assets can now add a +1 to their existing score (instead of being an automatic 9), Venture Capital Trusts (VCTs) and Enterprise Investment Schemes (EISs) will still automatically receive a score of 9.

For past performance, firms must ensure that where CCIs have materially changed objectives and benchmarks, performance is shown against the original benchmark. Monthly data points are now required for past performance charts (replacing quarterly), and pre-merger performance is not needed for merged funds. Firms remain responsible for ensuring past performance descriptions are fair, clear, and not misleading.

Key actions and considerations for firms

Where technical changes are concerned, a good first step for firms would be to do a gap analysis against their existing technical capabilities. First line functions should get second opinions from risk and compliance functions on the presentation and narratives of technical metrics.

Firms should also engage early with any outsourced providers they use for large-scale reporting to ensure that they are aligned on the approach to CCI and prepared for the go-live date.

3.3 Inclusion of narratives in core information metrics

Manufacturers will be required to include narratives alongside their prescribed technical metrics disclosures and can voluntarily include contextual information to supplement the metrics. For example, the Product Summary should contain statements on the importance of costs and charges and explain how costs affect product performance. Additional contextual information on costs can also be included and, although not mandatory, firms will still need to decide on the need for such additional disclosures. Manufacturers will also need to write concise risk descriptions of products alongside the risk and return indicator, which describe the factors that could affect the risk and return profile of the product and its performance.

Key actions and considerations for firms

Firms will need to determine what additional information to provide and how to approach these narratives. The technical information will need to be conveyed in a manner that is simple, engaging and informative. In the absence of a template, firms will need to create a framework around how disclosures should be designed, how much detail should be included and what terminology is most appropriate.  Firms will need to use the Duty’s guidance around layering information, considering the information’s relevance, and ensuring it is engaging to the target market.

4. Interaction with the Duty, SDR and Advice Guidance Boundary Review

Although the CCI regime offers greater flexibility on disclosures relative to the current regime, it comes with potentially greater risks as the design and delivery of CCI disclosures will need to meet Duty standards and will require firms to apply judgement to their decision-making.

In addition, there are other regulatory initiatives that interact with the CCI regime and firms should consider them carefully as part of their CCI implementation. These related initiatives include:

• Duty developments: the FCA is consulting in the first half of 2026 on changes   to rules on the application and requirements of the Duty. This consultation will include how firms work together in distribution chains and on the sharing of information through the chain.
• SDR: the FCA has suggested that manufacturers could include some general sustainability information from SDR disclosures in the product summary² . Check out our latest insights on SDR here.
• A new Targeted Support model: the FCA will be publishing final rules on its new Targeted Support regime in the coming days. In its TS Consultation Paper 25/17 the FCA highlighted the new model is intended to offer firms a “once in a generation” opportunity to rethink engagement and support for investment and pensions customers – read more here.

Key actions and considerations for firms

Firms should start by considering how the CCI regime will align with their existing Duty frameworks for delivering good outcomes, particularly on Price & Value, and Customer Understanding.

In relation to SDR, firms should consider specifically which sustainability information should be taken from SDR disclosures to include in CCI disclosures.

Firms that plan on using the new Targeted Support model should also pro-actively consider what disclosures they might use to support it, and how this might align with CCI disclosures.

Conclusion

The CCI disclosure regime will affect both manufacturers and distributors and present firms with a chance to revamp their retail communications strategy. However, there is a significant risk that the increased flexibility and lack of detailed rules on templates, the timing, and medium of disclosures will create an increase in supervisory challenge post-implementation and scrutiny of retail investment disclosures. The increase in information flows through the distribution chain in the shape of the Core Information Disclosures machine-readable document could also result in increased scrutiny of fair value assessments.

Firms have until early June 2027 to transition to the new regime, at a time when they will also have to prepare to implement other connected regulatory change initiatives. Both distributors and manufacturers will have to assess how to best deliver disclosures and communications that customers understand. This means they will need to monitor and test customer understanding to demonstrate Duty compliance in this area. Customer understanding might prove to be increasingly important for commercial success as the regulator moves to broaden the range of investments that will be accessible to retail clients.

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References

1 “CCIs are broadly products where the returns that may be received by the investor are dependent on the performance of indirect investments (meaning underlying or reference assets).” FCA’s CP24/30 para 3.2.

2 FCA’ CP24/30 paragraphs 2.38 and 2.39