The Consumer Composite Investments (CCI) regime: How we can help

The FCA’s December 2025 package of measures represents a significant reshaping of the UK’s retail investment disclosure framework.

Our Financial Services Regulatory team has deep experience advising asset managers, investment platforms, insurers and other market participants on product disclosure, client categorisation, Consumer Duty implementation and regulatory change programmes. We are well placed to support firms across the following areas.

Consumer Composite Investments 

READINESS AND GAP ANALYSIS
We can help firms assess their current state of preparedness for the CCI regime, including:

• Reviewing existing disclosure documentation and identifying gaps against the new DISC requirements

• Assessing cost, risk and performance calculation methodologies and identifying where changes are needed

• Evaluating current data flows between manufacturers and distributors and identifying enhancements required to meet the new machine-readable data obligations

• Advising on whether products should be repositioned as non-retail to fall outside the scope of DISC
  
  

PRODUCT SUMMARY DEVELOPMENT
We can assist manufacturers in developing product summaries that meet the requirements of the new regime and the FCA’s expectations under the Consumer Duty, including:

• Advising on the mandatory content requirements and how to present standardised information on costs, risk and return, and past performance

• Reviewing draft product summaries for compliance with DISC and alignment with Consumer Duty outcomes

• Advising on the approach to product summaries for share classes, multi-option products and fund-of-funds structures

• Supporting consumer testing to assess whether product summaries are meeting their intended purpose
  
  

METHODOLOGY AND DOCUMENTATION
The CCI regime gives manufacturers greater flexibility, but the FCA expects firms to exercise and document their judgment carefully. We can assist with:

• Documenting cost calculation methodologies, including the treatment of transaction costs, pull-through costs and performance fees

• Advising on risk and return score calculations, including the approach to adjustments and the treatment of illiquid assets

• Preparing methodology statements and internal policies to evidence compliance
  
  

DISTRIBUTOR OBLIGATIONS
We can assist distributors in understanding and meeting their obligations under the new regime, including:

• Advising on pre-sale disclosure obligations and how to highlight key information effectively within consumer journeys

• Reviewing additional product communications for consistency with the product summary and compliance with the fair, clear and not misleading standard

• Advising on the treatment of overseas products and any additional information that may be appropriate for consumers

• Preparing for the ingestion and use of machine-readable data from manufacturers
  
  

UNAUTHORISED FIRMS
The CCI regime brings unauthorised manufacturers and distributors within the FCA’s regulatory perimeter for the first time through the Designated Activities Regime. We can assist unauthorised firms with:

• Understanding their new obligations under DISC, including the general principles (equivalent to FCA Principles 1, 2, 3, 10 and 11), product governance requirements and complaints handling

• Establishing policies, procedures and governance arrangements to meet the new requirements

• Preparing for FCA supervision and the potential exercise of enforcement powers under FSMA
  
  

CCI TRANSITION PLANNING
We can help firms plan and execute their transition to the new regime, including:

• Developing a phased transition plan aligned to the April 2026 optional start date and June 2027 go-live

• Advising on the approach to new product launches during the transitional period

• Supporting operational readiness for handling both legacy disclosure documents and new product summaries

• Coordinating with other workstreams, including any parallel EU PRIIPs compliance obligations
  
  

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Client categorisation

CLIENT BOOK REVIEW AND RECATEGORISATION
The FCA’s proposals will require firms to review all existing elective professional clients against the new standards within 12 months of the rules coming into force. We can assist with:

• Analysing existing client books to identify elective professional clients and the basis on which they were originally categorised

• Assessing which clients are likely to meet the new threshold and which may require recategorisation or enhanced documentation

• Advising on the new £10 million wealth route and whether it is appropriate for your client base and business model

• Developing a recategorisation project plan and supporting its execution

POLICIES, PROCEDURES AND DOCUMENTATION
The new regime places greater emphasis on qualitative assessment and informed consent. We can help firms with:

• Reviewing and updating client categorisation policies to reflect the Relevant Factors framework

• Drafting or revising categorisation questionnaires and assessment templates

• Developing informed consent documentation that meets the new requirements (signature, sufficient information, sufficient time, clear and prominent warning)

• Advising on record-keeping obligations an dhow to evidence a robust assessment process

FIRMS WITHOUT RETAIL PERMISSIONS
Firms that do not hold retail permissions face particular challenges where existing clients cannot be recategorized as professional. We can advise on:

• The process for communicating with affected clients

• Winding down existing positions in accordance with the client’s best interests

• Options for obtaining retail permissions, third party authorisation routes or restructuring client relationships
  
  

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Consumer Duty: co-manufacturing and distribution chains

 
CO-MANUFACTURING AND DISTRIBUTION ARRANGEMENTS
Where multiple firms are involved in manufacturing or distributing products or services for retail customers, the regime requires clear allocation of responsibilities. We can help with:

• Drafting and negotiating co-manufacturing agreements that allocate DISC obligations appropriately

• Reviewing and updating distribution agreements to reflect the new information-sharing requirement

• Advising on the respective responsibilities of Boards and AIFMs for closed-ended investment funds

• Advising on complaints handling arrangements, including the assignment of responsibility to AIFMs where appropriate

SIMPLIFICATION REVIEW
The FCA’s statement suggests that some firms have built compliance frameworks that exceed what the rules require. We can assist firms in reviewing their current approach and identifying opportunities to simplify, including:

• Assessing whether existing processes assume joint decision-making or equal allocation of responsibilities where this is not required

• Advising on the extent to which firms can rely on other regulated firms in the distribution chain

• Reviewing documentation and governance arrangements to remove unnecessary duplication

OUTSOURCING INTERACTIONS
The interaction between outsourcing rules and co-manufacturing rules remains complex. We can advise on:

• How SYSC outsourcing requirements interact with Consumer Duty obligations where the service provider is itself authorised

• Preparing for the FCA’s H1 2026 consultation on clarifications to these rules
  
  

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Customer journey review 

PRE-SALE AND POINT-OF-SALE COMMUNICATIONS
Both the CCI regime and the Consumer Duty place significant emphasis on how firms communicate with consumers throughout the investment journey. We can assist with:

• Mapping existing customer journeys and identifying where disclosure touchpoints occur

• Reviewing pre-sale communications, including websites, apps and marketing materials, to ensure that key information is highlighted effectively

• Advising on the presentation of cost, risk and performance information at each stage of the journey

• Assessing whether additional product communications (such as layered information, personalised illustrations or explanatory graphics) would support informed decision-making.

CONSUMER TESTING
The FCA expects firms to test whether their communications are meeting their intended purpose. We can support:

• Designing and conducting consumer testing for product summaries and other key communications

• Reviewing testing methodologies and outcomes

• Advising on how to act on testing results and document the firm’s response

DIGITAL ENGAGEMENT PRACTICES
In light of the FCA’s discussion paper on expanding consumer access to investments, firms operating trading apps or digital platforms may wish to review their use of digital engagement practices. We can advise on:

• Assessing whether design features such as notifications, default amounts or gamification elements are consistent with Consumer Duty obligations

• Reviewing appropriateness testing processes and their integration into the customer journey

• Preparing for potential future regulatory intervention in this area

CONSULTATION AND DISCUSSION PAPER RESPONSES
We can assist firms in engaging with the FCA’s consultations and discussion papers, including:

• CP25/36 on client categorisation (responses due 2 February 2026)

• DP25/3 on expanding consumer access to investments (responses due 6 March 2026)

The anticipated H1 2026 consultations on Consumer Duty co-manufacturing rules

We can help firms articulate their views on the proposals, identify unintended consequences and present constructive alternatives to the regulator.

TRAINING
We can provide tailored training sessions for boards, senior management and operational teams on:

• The key features of the CCI regime and how it differs from PRIIPs and UCITS

• Manufacturer and distributor responsibilities under DISC

The interaction between CCI obligations and the Consumer Duty

Practical compliance considerations and common pitfalls

ONGOING SUPPORT
Beyond initial implementation, we can provide ongoing support to help firms maintain compliance, including:

• Advising on annual product summary reviews and updates

• Monitoring regulatory developments and FCA supervisory expectations

• Assisting with any regulatory queries or enforcement matters relating to CCI obligations

To discuss how we can support your firm’s CCI implementation, please contact Jamie Gray or another member of our Financial Services Regulatory team.

Key Contacts

 

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