On 8 December 2025, the Financial Conduct Authority (FCA) published Policy Statement PS25/20, introducing final rules for Consumer Composite Investments (CCI). This new framework will replace the PRIIPs and UCITS disclosure regimes with a single, consumer-focused approach. The FCA’s objective is clear: empower retail investors through transparent, concise, and timely information. The CCI regime forms part of a broader package of consumer investment reforms aligned with the Consumer Duty.

What Is Changing?

The FCA’s new CCI regime introduces a product summary as the cornerstone of disclosure. The CCI is designed to provide consumers with clear, comparable, and relevant information in a more engaging format. Unlike the PRIIPs template, the product summary allows firms flexibility in presentation while maintaining standardized content for key metrics.

The product summary must include:

Costs and Charges
The headline figure will be the Ongoing Cost Figure (OCF), which gives consumers a clear view of recurring charges. This will be supported by details of transaction costs and one-off costs, ensuring transparency across all cost components. The FCA’s aim is to simplify cost disclosure so that consumers can easily compare products without being overwhelmed by technical jargon.

Risk and Return
The regime introduces a new 1-10 risk scale, replacing the PRIIP SRI 1-7 scale. This is intended to provide a more granular and accurate representation of risk. For simple products like funds, the risk class is determined directly by the 10-year volatility of the product price. For structured products, the FCA mandates the use a Value-equivalent-Volatility (VEV) methodology, which reflects the potential variability in returns at maturity.

Past Performance
Instead of hypothetical scenarios, the CCI regime requires a 10-year historical performance graph, including monthly data points and benchmark comparisons where relevant. This approach gives consumers a realistic view of how the product has performed over time, supporting informed decision-making.

General Information
The summary must also include practical details such as complaints handling procedures, FSCS coverage, and any early exit penalties. These elements ensure that consumers understand not only the financial aspects of the product but also their rights and protections.

PRIIPs vs CCI Comparison – Key differences

Compliance Timeline

The 18-month implementation window starts now! Firms should use the time from now until April 2026 to prepare systems, templates, and processes.

Implications for Manufacturers vs Distributors

Manufacturers are responsible for creating the product summary, which is the cornerstone of the new disclosure regime. This means they must:

• Design and produce product summaries that meet FCA minimum content standards.
• Ensure accurate cost calculations, including OCF and transaction costs, to avoid misleading consumers.
• Implement new risk methodologies, such as the volatility-based scale and VEV model for structured products.
• Guarantee data availability for 10-year historical performance and benchmarks, which requires robust data management systems.

Distributors are the consumer-facing link and must ensure that product information is delivered clearly and at the right time. They need to:

• Integrate product summaries into consumer journeys, making disclosures accessible and understandable.
• Highlight key information pre-sale, aligning with Consumer Duty principles.
• Establish data-sharing processes with manufacturers for machine-readable formats to ensure consistency.
• Train staff on new disclosure requirements and consumer-centric communication.
• Both groups must collaborate closely to ensure consistency across the distribution chain. The flexibility offered by the CCI regime is an opportunity to enhance consumer experience, but only if manufacturers and distributors align on data standards, timing, and presentation.

Additional Insights from FCA Policy Statement

The FCA has introduced an optional transition period starting April 2026, allowing manufacturers to choose between the new CCI product summary and the existing PRIIPs/UCITS disclosure requirements. This flexibility is designed to give firms time to adapt systems, train staff, and test new templates before full implementation in June 2027. Until April 2026, early adoption during the transition phase can help firms identify gaps and optimize consumer journeys without regulatory pressure.

Consumer Duty Alignment: The FCA explicitly links the CCI regime to Consumer Duty principles, operationalizing obligations such as acting in good faith, avoiding foreseeable harm, and enabling informed decisions.

Overseas Funds Regime (OFR): Manufacturers of OFR schemes can also use the transition option, which introduces cross-border compliance considerations. Firms distributing overseas funds in the UK must align disclosure practices with CCI requirements while managing differences in other jurisdictions.

Risk Methodology Shift: The move from scenario-based projections under PRIIPs to historical data under CCI represents a significant methodological change. The new 1–10 risk scale is based on 10-year volatility, and structured products will use the Value-at-End (VEV) model.

Supervisory Focus: The FCA has signaled that it will monitor compliance closely, with particular attention to:

• Clarity of risk disclosures
• Cost transparency
• Consumer understanding testing

Industry Impact

The changes introduced by the CCI regime will require significant operational adjustments for both manufacturers and distributors. These adjustments go beyond updating templates and touch on core processes, data infrastructure, and compliance frameworks.

• Data Management: Firms must ensure access to extended historical performance data and accurate cost calculations.
• Risk Methodology Updates: Adoption of the volatility-based risk scale and VEV model for structured products.
• Consumer Duty Alignment: Disclosures must be clear, jargon-free, and demonstrably support informed decision-making.

Next steps

The PRIIPs Regulation has been in force since 2018, with the latest RTS updates implemented in 2023. Our KID Compliance Services are already aligned with these updates, meaning no additional changes are required for KID compliance in Europe. However, UK-based firms or firms with manufacturing and advisory business in the UK should begin planning for CCI now.

cleversoft Services

At cleversoft, we provide an end-to-end UK CCI Compliance Solution to support compliance with the CCI regime:

• KID Compliance: Automated generation of compliant product summaries.
• Data Integration: Machine-readable files for distributors to streamline delivery.
• Cost and Risk Calculation Modules: Ensure accuracy and compliance with FCA methodologies.
• Consumer Journey Optimization: Tools to test and improve disclosure effectiveness under Consumer Duty.

Our Regulatory Watch follows all developments. As part of our compliance commitment, we are happy to offer our customers continuously evolving regulatory services that take into account regulatory changes and new disclosure requirements.

Further information on our KID Compliance Services can be found on our website. If you have any questions, please contact our team of experts via the web form.