The CCI Regime: five strategic questions every firm should be asking

The FCA’s new Consumer Composite Investments framework is more than a compliance exercise; it marks a fundamental reset of how the UK retail investment market communicates with consumers.

The firms that recognise this will find opportunity, whereas those that don’t may find themselves playing catch-up for years. 

On 8 December 2025, the FCA published Policy Statement PS25/20 on Consumer Composite Investments (“CCI”) with final rules that replace the PRIIPs KID and UCITS KIID with a new, flexible disclosure framework for retail customers. The key points are straightforward: mandatory compliance by 8 June 2027, optional early adoption from 6 April 2026, the Ongoing Charges Figure ("OCF") becomes the primary cost metric, and a final goodbye to the rigid three-page template . 

However, arguably, the real story lies deeper. After processing 320 consultation responses across two papers (CP24/30) and CP25/9), the FCA has created something which is genuinely novel: an outcomes-based disclosure regime that grants firms design freedom while holding them accountable for whether their disclosures actually work. 

For asset managers, wealth managers, and distributors, this creates the following strategic questions that deserve board-level attention.

Question 1: Is disclosure about to become a competitive battleground?

For more than a decade, the KIIDs and KIDs have reduced disclosure to a tick box exercise. Every KIID/KID looked the same because the templates demanded it. The key difference was in what products you offered, not really how you explained them. 

The CCI regime changes this fundamentally. Manufacturers now have “considerable freedom over the design of product summaries” with no prescribed format, page limits, or mandatory layout. The FCA requires specific content for costs, risk scores, performance data and warnings, but it leaves presentation entirely to firms’ discretion.

This creates a new competitive arena. Firms that invest in consumer research, behavioural design and genuinely engaging communication may find that they can differentiate their products in ways that previously were not permitted. In this way, the product summary becomes an expression of brand beyond a regulatory disclosure document. 

Consider the implications: a boutique active manager could design disclosures that tell a compelling story about its investment philosophy and process. Similarly, a passive provider could create a paired-back, clear and focused summary that reinforces its low-cost positioning. And a thematic fund could use visual design to communicate its strategy more effectively than any template ever could. 

The question for leadership teams: are you treating CCI as a compliance project or a brand opportunity?

Question 2: What does the OCF decision really mean for product positioning?

The FCA’s decision to make the OCF the headline cost metric, and in doing so separate transaction costs entirely, represents a significant victory for the industry. It also creates new competitive dynamics that require careful thought. 

The decision to eliminate implicit transaction cost calculations removes one of PRIIPs’ more problematic elements. No more “negative costs” for investment trusts, nor pseudo-precise figures derived from bid-ask spread estimates that risked confusing rather than informing investors. The Investment Association’s consumer research has proved influential here: retail investors found that additional transaction cost information “detracted from the significance of the OCF” without helping them make better decisions. 

But the corollary of this is that the OCF now stands alone as the primary cost comparison metric. For active managers, this intensifies the conversation on “cost versus value”. The FCA’s stated outcome is that investors should “choose lower-cost products where appropriate”. While this has drawn criticism for failing to reflect a fuller assessment of value, the regulatory direction of travel is clear. 

For investment trusts and closed-ended funds, the news is more positive. The FCA excluded gearing costs and real asset maintenance expenses from OCF calculations. These are meaningful wins after years of campaigning by participants and associations. Funds investing in other closed-ended vehicles no longer face synthetic OCF aggregation requirements that some have criticised for apparent “double counting”. 

The strategic question is this: how does your product range look when the OCF is the primary comparison point, and what’s your narrative for products where the numbers alone do not tell the story? 

Question 3: How will the manufacturer-distributor relationship need to evolve?

The final rules create a cleaner but more rigid separation between manufacturer and distributor responsibilities than anticipated. In particular, the FCA changed its rules so that distributors cannot create or amend product summaries (a departure from the original proposal to permit distributors to tailor product summaries to their customers). Instead, distributors must deliver manufacturer documents unamended and are expected to build “compelling consumer journeys” using manufacturer data and must “highlight key information” pre-sale. 

Arguably, this creates asymmetric dependencies. On one hand, large platforms gain flexibility because they can differentiate through superior information architecture and comparison tools as well as contextual presentation, without taking on liability for product summaries. Hargreaves Lansdown or Interactive Investor can compete on how effectively they present manufacturer information, not just which products they offer. 

Smaller distributors, on the other hand, face a different reality. They are entirely dependent on manufacturers producing high-quality, Consumer Duty-compliant summaries. They cannot adapt disclosures to their specific client bases. If a manufacturer produces a poor product summary, the distributor has limited recourse beyond raising its concerns and hoping for changes to be made. 

There is some relief here. Alongside the CCI rules, the FCA published a statement on firms working together, which acknowledges that some have been over-interpreting requirements. The clarifications are helpful in setting out that firms can rely on each other without duplicating effort, joint decision-making is not required where roles are distinct, responsibilities can be allocated unequally, and liability generally follows causation rather than extending across the chain. On the other hand, the FCA announced a consultation in the first half of 2026 on potential amendments to these rules. This means that the underlying Consumer Duty framework or multi-firm arrangements may shift just as CCI goes live. Smart firms will design flexibility into their agreements and processes now. 

The machine-readable data requirement becomes crucial here. Manufacturers must provide Core Information Documents in formats which distributors can consume programmatically. The quality and timeliness of this data will undoubtedly increasingly influence distribution relationships. Distributors may start favouring manufacturers whose data feeds integrate smoothly with their own systems. 

For manufacturers: how will you ensure your product summaries are genuinely useful to distributors, not just technically compliant?

For distributors: which manufacturer relationships will need renegotiation, and how will you differentiate your presentation layer in the customer journey?

Question 4: What does Brexit divergence actually mean for your operating model?

The CCI regime crystallises genuine regulatory divergence from the EU – not just different rules, but a different philosophy. The UK has chosen outcomes-based flexibility whereas the EU maintains prescriptive standardisation. For firms operating across both markets, this creates a kind of lasting structural complexity. 

There are significant practical implications to regulatory divergence:

• Dual documentation production. UK product summaries and EU PRIIPs KIDs will look nothing alike. They use different formats, risk scales (1-10 vs 1-7), performance presentations (past performance graphs vs probabilistic scenarios), and cost calculations (excluding vs including implicit transaction costs).
• Dual compliance programmes. CCI and Consumer Duty requirements apply to UK disclosures whereas harmonised, prescriptive PRIIPs requirements apply to EU disclosures. The governance, testing and monitoring processes for both disclosure channels may need to operate in parallel.
• Dual data infrastructure. The machine-readable outputs required for UK CCI and EU EPT templates differ in structure and content. In short, systems which are built for PRIIPs may not readily translate to CCI. 

For EU managers distributing into the UK under the Overseas Funds Regime, the burden compounds further. They face existing home-state PRIIPs requirements plus new UK CCI obligations, plus Consumer Duty-equivalent standards for UK retail clients. At some point, this compliance arithmetic begins to influence distribution strategy and regulatory structuring decisions. 

The hard question: does your UK/EU retail market participation still make economic sense given dual compliance costs, or should resources focus elsewhere?

Question 5: Is 18 months actually enough time?

The implementation timeline has drawn consistent industry concern – and for good reason. From rule publication to mandatory compliance, firms have 18 months to do the following:

• Evaluate and design the CCI operating model
• Redesign product summaries from scratch (no template means starting with a blank page)
• Build or procure systems to produce machine-readable Core Information Documents
• Recalculate cost figures using new methodologies
• Establish/update manufacturer-distributor information-sharing protocols
• Train staff on new requirements
• Test disclosures against Consumer Duty outcomes (are they actually working?)
• Coordinate with fund administrators, data vendors, and technology providers.

This happens while firms must simultaneously manage SDR implementation, MiFID organisational regulation changes, Targeted Support proposals, potential changes to the Transaction Reporting regime, and ongoing Consumer Duty developments. The regulatory change agenda has not paused for CCI.

The FCA’s cost estimates (£48.8 million for manufacturers over ten years) have been questioned as significantly understated. These figures exclude unquantified ongoing costs and entirely omit distributor implementation expenses. TISA has estimated data infrastructure costs of approximately £200,000 per firm based on SDR experience; CCI may require even more data points. 

Early movers face a different calculation. The optional adoption window from April 2026 offers potential advantages such as early market positioning, the ability to refine processes before mandatory deadlines, and the potential for distributor preference for firms that demonstrate a track record for CCI-readiness. But it compresses timelines further. 

The planning question: have you scenario-tested your implementation timeline, and what is your contingency if it slips?

The bigger picture: disclosure as strategy

The final rules for the CCI regime arrive at an inflection point for UK retail investment. The FCA’s broader agenda focuses on boosting retail participation, simplifying the advice guidance boundary and encouraging appropriate risk taking. This depends partly on disclosure that actually engages consumers rather than overwhelming them with compliance-driven boilerplate. 

The flexibility that the FCA has granted is, in this sense, a test. Can the industry produce disclosures that genuinely help the 12.5 million UK adults holding composite investments to make better decisions? Or will firms produce minimal compliance documents that look different from PRIIPs KIDs but work no better?

The answer may shape regulatory attitudes for years to come. If flexibility is a success, this might encourage further flexibility and reduced prescription. However, if there is evidence that consumers remain confused or misled despite design freedom, then it would likely prompt a supervisory response under Consumer Duty powers that extend well beyond disclosure. 

An approach that goes beyond compliance for forward-thinking firms:

Invest in understanding your consumers. The FCA’s behavioural testing found existing KIDs “not engaging”. What would engage your specific investor base? Generic design assumptions may not be sufficient. 

Treat the product summary as a brand touchpoint. If you have 18 months to redesign how you communicate with retail clients, use it. The document you produce will be seen by every investor, every year. 

Build for iteration. Consumer Duty requires ongoing monitoring of outcomes. Design your disclosure processes to accommodate testing, refinement, and improvement over time. 

Engage distributors early. The new information sharing requirements mean manufacturers and distributors need to collaborate differently. Those relationships take time to establish. 

The CCI regime is not the most dramatic regulatory change the industry has faced. However, it may be one of the more consequential for how firms present themselves to retail investors. The question is whether firms will use the opportunity.

Related News, Insights & Events