Key takeaways:
- On 8 December 2025, the FCA published PS25/20, which confirmed the final rules for the Consumer Composite Investments (CCI) regime. CCI is the UK framework that replaces both the PRIIPs KID and the UCITS KIID with a single, outcomes-focused Product Summary
- CCI is optional from 6 April 2026 and mandatory from 8 June 2027. The FCA has deliberately not issued a template, so firms must now make a series of methodology and disclosure decisions, evidenced under the Consumer Duty
- For fund managers, the binding constraint is operational, e.g., recalculating risk scores on a new 1–10 scale, pulling through underlying costs, selecting or justifiably omitting benchmarks, and proving that disclosures genuinely help consumers. For private markets and closed-ended exposure, illiquidity and CEIF rules change how products are scored and presented
For years, Packaged Retail and Insurance-based Investment Products (PRIIPs) disclosure has essentially involved filling in the boxes. The Key Information Document had a fixed template, page limit, prescribed performance scenarios, and established risk scale. Compliance teams could populate the form correctly without too much fuss.
Under the UK’s new CCI regime, the FCA has intentionally removed the template and page limits, replacing them with an instruction: produce a Product Summary that genuinely helps a retail consumer understand the product, and make sure you can prove it does. Where PRIIPs told you what to write, the CCI regime makes you responsible for that decision—and for defending that decision under the Consumer Duty.
This article sets out what will change under CCI (PS25/20), what manufacturers and distributors must do before June 2027, and what this means for your operations in 2027 and beyond.
How the UK got here: From PRIIPs to CCI
The PRIIPs regime was originally an EU framework designed to help retail investors compare complex products. The UK adopted it as a member state, then onshored it after Brexit before initiating meaningful divergence.
In 2022, the FCA’s PS22/2 introduced a UK-specific version that replaced PRIIPs performance scenarios with performance “narratives” and clarified when a product is “made available” to retail investors. The UK also extended exemptions for UCITS/NURS KIIDs and introduced forbearance for investment trusts while it built a permanent replacement.
That replacement is the CCI regime. The underlying legislation, the Consumer Composite Investments (Designated Activities) Regulations 2024, became official in November 2024.
What is a CCI?
A CCI is defined broadly as any investment whose return depends on the performance or value of an underlying or reference asset. That definition captures open-ended funds, recognised funds, closed-ended investment funds (CEIFs), structured products and deposits, contracts for difference, and insurance-based investment products. Because the regime uses the Designated Activities Regime, it reaches unauthorised and overseas manufacturers as well as FCA-authorised firms.
What did the FCA change in PS25/20?
This is a summary of the substantive final rules, highlighting points where the FCA moved away from its earlier proposals.
Scope and the non-retail carve-out
The FCA clarified scope, particularly for corporate bonds. Plain vanilla listed bonds and bonds tracking EURIBOR or similar interbank rates are not CCIs. They also simplified the non-retail carve-out; a product falls outside the Product Disclosure sourcebook (DISC) where the manufacturer:
- Clearly marks communications and marketing as not for retail, and
- Takes steps to keep the product away from retail investors, including an appropriate distribution strategy.
Post-consultation change: The FCA dropped its earlier proposed £50,000 minimum-investment threshold for non-retail status. Firms that relied on that threshold to scope products will need to re-run the analysis against the behavioural test instead.
Costs and charges
The Ongoing Charge Figure (OCF) is the headline cost, shown both as a percentage and in pounds and pence. One-off costs must be shown prominently, but separately from ongoing costs. Costs, risk and return, and past performance must also be presented so consumers can compare across products.
Transaction costs
Explicit transaction costs must be disclosed as a number, presented separately from ongoing costs. Firms have flexibility in where this sits on the summary; for example, alongside an explanation of strategy rather than buried among other cost lines.
Pull-through (underlying) costs
Where a CCI invests in closed-ended investment funds (CEIFs), those costs must be transparent and clearly presented to consumers in the product summary. Costs are not added to the OCF, but must be disclosed transparently via a weighted average cost-to-NAV ratio, calculated on the same methodology used for other CCIs.
Post-consultation change: The FCA had proposed exempting passive funds from pull-through disclosure, but has since dropped the proposed exemption.
Risk and return
| Consideration | Under PRIIPs (As amended in 2022) | Under CCI (PS25/20) |
| Scale | 1–7 | 1–10 (1 = lowest, 10 = highest) |
| Volatility window | 5-year standard deviation | 10-year standard deviation |
| Low-liquidity products | Automatic score of 9 (proposed) | At least +1 to the score; no automatic 9 |
| VCTs | Automatic score of 6 | Automatic score of 9 |
Products with fewer than 10 years of returns must use simulated past performance, drawn from the underlying assets’ history or an appropriate benchmark. The FCA also softened its illiquidity stance: instead of requiring an automatic 9, manufacturers must add at least +1 where a product invests in illiquid assets or imposes a delay or added cost on retail investors withdrawing money. Leverage that crosses a high-risk threshold is a judgment for the manufacturer to make and justify.
Closed-ended investment funds (CEIFs)
The FCA engaged extensively with the CEIF sector and amended its original proposals so consumers can compare CEIFs against other options while the rules still accommodate their structure. The FCA has stated that the new regime gives CEIFs meaningful freedom to explain themselves to consumers in ways the rigid PRIIPs template never allowed.
Performance information
Past performance is shown on a standardised line graph over 10 years (or as long as data exists), based on a £10,000 initial investment (or non-sterling equivalent), net of costs. In some cases, benchmark information should also be included.
Manufacturer and distributor responsibility
The FCA has clarified core responsibilities for each role. Distributors are no longer passive recipients of manufacturer disclosures; they must apply their own judgment.
No Product Summary template
At the time of writing, there is no standard template for the CCI Product Summary, which is in line with the FCA’s intentions. Instead, they’re encouraging firms to innovate and design disclosures that support consumer understanding and positive outcomes. This could be more challenging than it first appears; regulators will measure disclosure effectiveness in addition to technical compliance.
Product Summary as financial promotion
Because the CCI Product Summary is a free-form document and not the prescribed (and exempt) PRIIPs KID, the FCA has removed the financial promotion exemption. Firms must approve Product Summaries as retail financial promotions.
The timeline: When does CCI come into effect?
- 8 December 2025: PS25/20 published, 18-month implementation period begins
- 6 April 2026: Legislation comes into force, and manufacturers may optionally adopt the CCI Product Summary
- 8 June 2027: Full CCI compliance is mandatory; PRIIPs KIDs and UCITS KIIDs cease
It is expected that most manufacturers will switch to the new Product Summary at the time of their annual refreshes in 2027.
What manufacturers need to do before 8 June 2027
- Build the Product Summary. A CCI-compliant summary replaces PRIIPs KIDs and UCITS KIIDs entirely, plus a machine-readable file (CSV) for distributors
- Recalculate the risk score. Move to the 1–10 scale and the 10-year standard deviation (or VEV model for structured products). Apply the +1 for illiquidity where relevant, and assign an automatic 9 to VCTs and EISs
- Write the risk and return narrative. Give consumers a plain-English explanation of the risks involved and the factors that drive performance
- Notify existing investors. Tell current retail investors about the change and explain why the risk score has moved; a higher number on a new scale will prompt questions
- Produce the past-performance graph. This is the net-of-costs line graph on a hypothetical investment, including a prominent warning explaining that past performance is not a guide to future performance
- Choose a benchmark or justify its absence. Select a relevant benchmark, or document a defensible explanation for omitting one
- Revisit complaints handling. Publish clear procedures, including how to complain, when a complaint may be forwarded, and any alternative dispute resolution route
- Recalibrate information-sharing with distributors. Distributors now exercise their own governance; the information you provide must support that decision-making
- Evidence Consumer Duty outcomes. Demonstrate that your disclosure produces clear, informed decision-making and is fit for purpose
How we can help
The FCA’s PS25/20 replaces PRIIPs KIDs and UCITS KIIDs with a more flexible, outcomes-focused regime that shifts responsibility toward firms to design and deliver product information that is clear, meaningful, and demonstrably aligned with the Consumer Duty.
Our UK Compliance Consultancy team supports manufacturers and distributors across the full transition by helping firms make and evidence the decisions the rules now require:
- Scoping which products are caught, and pressure-testing updated CCI documentation and processes
- Updated risk-and-return score methodology and cost pull-through, including CEIF and passive-fund positions
- Product Summary design and benchmark selection, with the governance trail to evidence good consumer outcomes under the Consumer Duty
- Distributor information-sharing and financial promotion approval, reflecting distributors’ new active role and the Product Summary’s status as a retail financial promotion
Contact our team to discuss your CCI readiness.
About the authors
Sarmad Naim and Suraj Ruparell are members of IQ-EQ’s UK Compliance Consultancy team, which advises fund managers, asset owners, and distributors on FCA regulatory change, product governance, suitability and appropriateness tests and Consumer Duty implementation. The team supports firms through complex regulatory transitions, from scoping with a methodology to governance while implementing robust systems and controls to evidencing, across the UK funds and private markets sectors.
Frequently asked questions
When does the CCI regime take effect?
The legislation commences on 6 April 2026, when manufacturers may optionally adopt the CCI Product Summary. Full compliance is mandatory from 8 June 2027.
Does CCI apply to overseas or unauthorised firms?
Yes, it captures any firm that manufactures or distributes a CCI made available to UK retail investors. This includes unauthorised and overseas manufacturers and operators of Overseas Funds Regime schemes.
Is there a standard template for the CCI Product Summary?
No, the FCA has deliberately chosen not to mandate a template, instead encouraging firms to design disclosures that genuinely aid consumer understanding. Firms must design and justify their own format, and may need consumer testing to prove that it supports good outcomes under the Consumer Duty.
Is the CCI Product Summary a financial promotion?
Yes. Unlike the exempt PRIIPs KID, the free-form CCI Product Summary is not exempt from the financial promotion restriction. Firms must approve it as a retail financial promotion or use someone with the relevant approver permission.
