CCI final rules: what you need to know

8 December 2025 marked a watershed moment for UK retail investment regulation. The FCA published PS25/20 setting out final rules for the Consumer Composite Investments (CCI) regime. This draws a definitive line under the PRIIPs and UCITS disclosure frameworks that have frustrated firms and confused consumers for years. 

The message from the regulator is clear: the era of rigid, template-driven disclosure is over. In its place comes a more flexible, outcomes-focused regime that puts the Consumer Duty at its heart and challenges firms to communicate with investors in ways that genuinely help them make decisions. 

Around 12.5 million UK adults currently hold a CCI, which makes this a regime with significant consumer reach. 

Scope, what’s in and what’s out

The CCI regime applies to packaged retail investments where returns depend on the performance of underlying or referenced assets. This captures a broad range of products and the list below is not exhaustive. Firms will need to assess whether their products fall within the CCI definition set out in DISC 1A.2.

The FCA has also simplified the criteria for treating products as non-retail. Manufacturers can now take products outside the DISC rules by clearly marking communications as “not for retail” and ensuring an appropriate distribution strategy that prevents retail distribution. The previously proposed £50,000 minimum investment threshold has been dropped. 

Distributors should note that under DISC 2A.3.1R they must not distribute a CCI to a retail investor unless an up-to-date product summary is available. This effectively means that products without a product summary cannot be sold to retail clients.
 

What’s changing and why it matters

The CCI “product summary” replaces the KID

The centrepiece of the new regime is the “product summary”. This is a manufacturer-produced document that must contain standardised information on costs, risk and return, and past performance. Beyond these core requirements, however, firms have freedom to design the document as they see fit. The prescribed templates, page limits and rigid formatting requirements of the PRIIPs KID have been removed. 

The FCA has made clear that it expects firms to use plain English rather than legal jargon, and to focus on information that genuinely assists consumers in making investment decisions rather than on technical compliance. This represents a significant shift in regulatory philosophy. Firms are being granted more latitude, but in return they are expected to exercise genuine judgement about what their customers need to know. 

Product summaries must be reviewed and updated at least once every 12 months. Manufacturers must also provide the underlying product data to distributors in a machine-readable format, although an exception applies where the manufacturer is the sole distributor of its own products.

The FCA has also relaxed some of the proposed rules on “downplaying” information in the product summary, in response to feedback that the original drafting was overly restrictive and could inhibit firms from providing balanced communications. The guiding standard remains that communications must be fair, clear and not misleading. 

Cost disclosure simplified

• Cost disclosure was among the most contested aspects of the consultation. The FCA has landed on a pragmatic position:
• The ongoing costs figure (OCF) becomes the headline metric and must be shown both as a percentage and in pounds and pence.
• One-off costs (such as entry or exit charges) and explicit transaction costs must be disclosed, but are to be presented separately from the OCF. This avoids the misleading impression that such costs are payable on an annual basis. Firms have the flexibility as to how transaction costs are presented and may, for example, place them alongside an explanation of the product strategy rather than with other cost information.
• Implicit transaction costs (including slippage and the bid-ask spread) are no longer required to be calculated or disclosed, which removes a significant compliance burden. The FCA has clarified that mark-ups and mark-downs are explicit costs and must be included.
• Gearing and real-asset maintenance costs are excluded from the OCF calculation across all CCIs.
• Zero-cost categories do not need to be included in the product summary, but manufacturers should provide written confirmation of zero costs to distributors in the underlying data file.
• Structured products with a maturity of less than one year should disclose costs over the lifetime of the product rather than on an annualised basis. 

For funds that invest in other CCIs, including CEIF, the costs of underlying holdings must be disclosed transparently. However, these costs need not be rolled into the investing fund’s OCF. This represents a notable concession to the investment trust sector, which argued that “pull-through” aggregation misrepresented the nature of their cost structures. The costs of underlying open-ended funds and ETFs continue to be pulled through into a synthetic OCF.

The FCA also expects performance fees in underlying CCIs (including CEIFs) to be disclosed together with any potential conflicts of interest where the same manager benefits from fees at both the investing fund and underlying fund level. 

The FCA has redrafted MiFID Org Reg Article 50 to ensure that product costs for MiFID pre- and post-sale disclosures are aligned with those required under DISC. Article 51 has been deleted as duplicative. A wider review of MiFID disclosure requirements is planned for 2026.

Risk becomes “risk and return”

• The FCA has rebranded its risk indicator as a “risk and return” score. This reflects feedback that disclosure should present a balanced picture of both downside risk and upside potential. The key changes are as follows:
• A 1-10 scale replaces the previous 1-7 range, which allows for more granular differentiation between products.
  Volatility of the product is now calculated over 10 years rather than 5 years. Products with less than 10 years of returns must use simulated past performance using the history of the underlying assets or an appropriate benchmark where that is not possible.
• Manufacturers are required to adjust the risk and return score where they consider that the calculated number does not appropriately reflect the product’s risk profile. The score should be increased where material risks such as credit risk or concentration risk are present. Downward adjustments are permitted only in limited circumstances, namely where there is at least 90% capital protection or where the initial calculation is unrepresentative (for example, due to a period of extreme market anomaly). Any downward adjustment should be made cautiously.
• Products with low liquidity must add +1 to their risk and return score. This replaces the previous approach under which such products were automatically assigned a score of 9. Low liquidity is triggered where either (a) a retail investor is likely to face delay or added cost when exiting, or (b) 50% or more of the underlying assets are illiquid. Where both criteria are met, manufacturers need only add +1 once. Products that invest in illiquid assets but are regularly traded on an exchange are exempt from this adjustment, on the basis that they have transparent market valuations and can typically be sold quickly. VCTs and EIS remain automatic 9s given their inherent risk profile.
• Structured products are required to use a value-at-risk equivalent volatility (VEV) methodology, which is better suited to their payoff profiles. This applies across the category, including capital guaranteed notes and structured capital-at-risk products (SCARPs). SCARPs with returns tied to multiple indices or featuring gearing were previously proposed to receive an automatic score of 9, but this is no longer required under the final rules. However, such products must still carry a complexity warning label to alert investors to the greater risk of misunderstanding.

Clearer division of manufacturer and distributor responsibilities 

Following strong pushback from respondents, the FCA has stepped back from proposals that would have allowed distributors to create or amend product summaries. The final position is as follows:

• Manufacturers are solely responsible for producing the product summary and must provide underlying data to distributors in a machine-readable format.
• Distributors must make the product summary available to consumers before the point of sale, must highlight key information to support decision-making, and must provide the document to consumers in a durable medium at or shortly after the point of sale.
• At the pre-sale stage, distributors are required only to highlight essential information. This includes a brief product explanation, the OCF and any other relevant costs, and the risk and return score together with appropriate warnings. Distributors are not required to present the full product summary at this stage.
• Distributors may provide additional product communications to supplement the product summary, such as layered information along the consumer journey, personalised illustrations of costs or performance, or explanatory graphics. The FCA encourages firms to consider what additional information might be helpful, including (for example) limitations on access to redress where the manufacturer is overseas. 

Where firms collaborate in manufacturing a CCI, they must set out their respective roles and responsibilities in a written agreement. The agreement may provide that one manufacturer is solely responsible for preparing and updating the product summary. 

The rules include certain modifications for specific distribution scenarios. Distributors are not required to provide the product summary where the CCI is distributed to or through a discretionary investment manager acting on behalf of the retail investor. Similarly, the distribution obligations do not apply where a distributor is acting on the instructions of another distributor who is its client. 

Firms throughout the distribution chain must cooperate and share information proactively to enable each firm to meet its regulatory obligations. The FCA has indicated that it plans to consult in the first half of 2026 on changes to the Consumer Duty rules relating to distribution chain cooperation, and that these changes will also apply to DISC. 

The 18-month implementation period applies to all CCIs. From April 2026, manufacturers will be able to choose whether to produce product summaries under the new regime or to continue with existing disclosure arrangements. 

During the transition period, manufacturers may continue to use existing KIDs or KIIDs provided that these documents continue to meet the requirements of the previous regime and are reviewed at least annually. Documents produced before 6 April 2026 can continue to be used on this basis. Importantly, UCITS funds will not need to transition to a PRIIPs KID at any point and can move directly from the KIID to the product summary. UK-listed closed-ended investment funds, which were carved out of the PRIIPs regime, are not required to produce any disclosure document during the transitional period. 

There is no requirement to convert existing documents to the new CCI format until the full go-live date, but all CCIs distributed to retail investors must have a product summary in place by 8 June 2027. 

Firms will need to manage the operational complexity that arises from having both legacy disclosure documents and CCI product summaries in circulation during the transition period. One practical approach may be to ensure that any new products launched from April 2026 are compliant from the outset, thereby avoiding the need to readjust disclosures shortly after launch. 
 

Practical implications

For manufacturers

• Scoping: Firms should finalise their assessments of which products fall within the CCI regime and should consider whether any products ought to be repositioned as non-retail
• Product summaries: Firms should begin designing summary documents that meet the new content requirements while taking advantage of the formatting flexibility on offer. Product summaries must be published on a publicly accessible website.
• Data infrastructure: Firms will need to build or adapt systems to produce machine-readable data files for distributors.
• Document methodologies: Firms should document their cost, risk and performance calculation methodologies carefully. The new flexibility comes with heightened expectations as to how firms exercise their own judgement.
• Co-manufacturing arrangements: Where firms collaborate in manufacturing a CCI, they should ensure that a written agreement is in place setting out their respective responsibilities under DISC.
• Annual review: Firms should establish processes to review and update product summaries at least once every 12 months. 

For distributors

• Consumer journey design: Firms should consider how to highlight key information at the pre-sale stage in ways that support informed decision-making under the Consumer Duty. There is scope to provide additional product communications alongside the product summary, such as layered information, personalised illustrations or explanatory graphics.
• Data ingestion: Firms should prepare to receive and process machine-readable product data from manufacturers.
• Transition planning: Firms should ensure that they have the operational readiness to handle both legacy disclosure documents and new product summaries during the transition period.
• Overseas products: Where distributing products from overseas manufacturers, firms should consider what additional information may be appropriate for consumer, including any limitations on access to redress.

For closed-ended investment funds

The CEIF sector secured several accommodations in the final rules, including the exclusion of gearing costs from the OCF and the requirement for separate (rather than aggregated) disclosure of CEIF costs in fund-of-funds structures. However, CEIFs remain firmly in scope of the regime. Boards and AIFMs should document clearly how CCI responsibilities are to be divided between them, and should begin planning for the production of product summaries. UK-listed CEIFs are not required to produce any disclosure document during the transitional period, but must have a product summary in place by 8 June 2027. Where the CEIF is a co-manufacturer with an AIFM, responsibility for complaints handling may be assigned to the AIFM if appropriate. 

For firms with EU distribution

Firms that distribute products to retail investors in both the UK and EU should note that the CCI regime applies only in the UK. The EU PRIIPs Regulation continues to apply to products distributed to EU retail investors. Such firms will need to consider how to manage parallel disclosure obligations efficiently, recognising that methodologies for costs, risk and performance may differ between the two regimes.

Looking ahead

The CCI regime forms part of a broader package of retail investment reforms, which includes upcoming rules on “targeted support” and a consultation on investor categorisation. Firms should view these developments holistically. The direction of travel is towards a more outcomes-focused Consumer Duty-aligned regulatory framework that rewards genuine attention to customer needs. 

The FCA has indicated that it will monitor the readability of disclosures, the accessibility of product information in consumer journeys, and retail investor understanding through the Financial Lives Survey. Supervision will focus on outcomes rather than on technical compliance alone. 

For firms that are willing to embrace the spirit of the reforms, the CCI regime offers a real opportunity to differentiate themselves through clearer and more engaging communications. For those that are inclined to treat it as a box-ticking exercise, the combination of Consumer Duty obligations and outcomes-focused supervision presents meaningful risk. 

For further information on how these changes may affect your business, please contact our Financial Services Regulatory team. 

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