Consumer Composite Investments (CCI)

Background

Following Brexit, the UK brought the PRIIPs (Packaged Retail and Insurance-based Investment Products) and UCITS (Undertakings for Collective Investment in Transferable Securities) disclosure regimes into domestic law, enabling the UK to replace the EU-derived framework with a UK-specific regime. This was subsequently put into effect in December 2022, when HM Treasury set out its intention to repeal the UK PRIIPs disclosure regime and replace both PRIIPs and UCITS retail disclosure requirements with a new framework. This move saw the introduction of the new CCI (Consumer Composite Investment) legislation, an over-arching framework to be enforced by the Financial Conduct Authority (FCA). The CCI legislation commences on 6 April 2026, which opens an 18-month optional transitional period where firms may choose to use the new regime. The FCA’s rules then come fully into force on 8 June 2027, by which date in scope firms must have transitioned.

Approach

Following several consultations and discussion papers, the UK government published the Consumer Composite Investments (Designated Activities) Regulations 2024. These regulations establish a designated framework under the Financial Services and Markets Act 2023 for firms that manufacture, offer, or advise CCI to UK retail investors. The detailed disclosure requirements are then set by the FCA through its Handbook rules and guidance.

The FCA has subsequently published final rules and guidance (PS25/20), establishing how firms must comply with the CCI regime in practice. The framework is designed to be focused more on outcomes rather than prescribed templates, as was the case with previous disclosure requirements.

Analysis

Scoping

Definitions: Key terms are defined and aligned where possible with UK domestic law. In particular, the concept of a PRIIP is replaced with products in the scope of the CCI framework. While the scope is largely comparable to PRIIPs, it is framed to allow the FCA flexibility to tailor coverage through its rules, including UK authorised funds and certain overseas funds marketed under the Overseas Funds Regime.

Products: A CCI is an investment where the returns are dependent on the performance of, or changes in, the value of underlying or reference assets. This explicitly includes open ended funds, closed ended funds, recognised funds, structured products and structured deposits, contracts for difference (CFDs), insurance-based investment products (IBIPs) and other complex products like derivatives. Vanilla corporate bonds, pension products and pure protection insurance contracts are specifically excluded from scope.

Designated activities: The regulations define the manufacturing, offering or advising on a CCI to UK retail investors as designated activities under the Financial Services and Markets Act 2023. Firms engaging in these activities are subjected to FCA rules made under the CCI framework, regardless of whether they are manufacturers or distributors.

Regulatory compliance

FCA powers: The FCA has powers to make, supervise and enforce rules concerning designated activities, allowing them to determine the content, form, and presentation of retail disclosures through its Handbook rather than primary legislation.

Civil liability: The regime allows private claims for certain breaches of the FCA’s DISC (Product Disclosure sourcebook) rules, but not every instance of non-compliance automatically creates liability. For the product summary in particular, liability is limited to those who tabled it — commonly the manufacturer — and only where it is misleading, inaccurate, or inconsistent in context.

Disclosure framework

KID/KIID: The CCI regime moves away from the Key Information Document and Key Investor Information Document templates. Instead, manufacturers are required to produce a product summary that supports investors’ decision-making and aligns with Consumer Duty outcomes. The FCA places emphasis on clarity, relevance, and consumer understanding rather than strict standardisation.

Calculation methodology: These are now contained in the FCA Handbook, allowing flexibility and reducing reliance on exact or potentially misleading metrics used under PRIIPs.

Key changes

Instead of a KID/KIID template, manufacturers must prepare a document labelled ‘product summary’, which contains:

General product information

• Key information, such as product name/identifier, manufacturer and date.
• Complaints and compensation scheme information.
• Minimum holding period warning, early exit fees, and where to find more information.

Risk

Manufacturers must produce a 1-10 risk and return score, replacing the 1-7 scale used under PRIIPs/UCITS. The score is based on the FCA’s prescribed volatility calculation methodology and ranking grid.

This must be accompanied with a risk and return description of the product, which aims to help consumers better understand the risks involved and the factors that might affect performance.

Performance

Where a CCI has past performance information, the manufacturer must include a line graph showing performance over the relevant period, being the shorter of the past 10 years and the period for which past performance information is available.

The graph must use monthly datapoints and assume an initial investment of £10,000.

Where the available performance period is 1 year or less, a short-period warning must be included. Where it is less than 3 months, the manufacturer may instead state that there is insufficient performance information to usefully illustrate performance.

Costs

Costs and charges must be categorised as one-off entry costs, one-off exit costs, ongoing costs and transaction costs, with performance fees and carried interests disclosed separately.

Explicit transaction costs must be disclosed numerically and presented separately from ongoing costs, rather than being aggregated into a single summary figure.

The costs of underlying CCIs will generally continue to be pulled through into the ongoing costs figure, but the ongoing costs of investee closed-ended investment funds do not need to be aggregated and must instead be disclosed separately.

One-off and ongoing cost figures must generally be presented both as percentages and cash amounts, while transaction costs are shown as a percentage figure. Performance fees and carried interests must be described in plain English and illustrated with at least one worked example.

Conclusions

The CCI Regulations are one of the ways that the UK Government are tailoring regimes to the UK market whilst enabling the UK to stay competitive. It replaces the prescriptive KID/KIID requirements with a more outcomes-based framework aligned with Consumer Duty. The FCA estimates 778 manufacturers, and over 5,000 distributor firms will be impacted by these changes (FCA, 2024; p79).

Impacted firms should be aware of the following:

• The scope of the new regulations: Products and activities previously not covered under PRIIPs may now fall under the scope of CCI.
• FCA's regulatory powers and the compliance risks under CCI: Firms should fully understand these and conduct the necessary compliance assessments.
• Differences in required disclosures: For firms with both UK and EU presence, a decision will need to be made on whether to comply with different disclosure frameworks or leverage the existing ones from EU PRIIPs.
• The regime begins to apply from 6 April 2026, commencing an 18-month transitionary period, and will be fully in force from 8 June 2027.

PryceWilliams continues to monitor FCA supervisory expectations and implementation developments as firms prepare for transition.

Recommendations

To prepare for the incoming regulations, firms should:

• Horizon Scanning: Understand and familiarise yourself with the requirements and developments as they are published.
• Review: Assess current practices and the fund landscape to understand the potential impacts and challenges.
• Contact: PryceWilliams are experts in regulatory change. Contact us to understand how we can work together to ensure the smooth implementation of the changes.

Next Steps

PryceWilliams provides specialist consulting and project delivery services for organisations undergoing strategic change, regulatory compliance and technology transformation needs. Our focus is on supporting the project sponsor to ensure project implementation is delivered on time and within budget. Should you need support, contact us to make progress happen.

References

• Financial Conduct Authority (2024) CP24/30: A new product information framework for Consumer Composite Investments. [pdf] Available at: https://www.fca.org.uk/publication/consultation/cp24-30.pdf [Accessed 27 March 2026].
• Financial Conduct Authority (2026) DISC: Product Disclosure sourcebook. [pdf] Available at: https://api-handbook.fca.org.uk/files/sourcebook/DISC.pdf [Accessed 27 March 2026].