UK-CCI: a game-changer looms

This article outlines the main elements of the new UK Consumer Composite Investments (CCI) rules, sets out the key challenges, and explains how we can help firms prepare for the FCA’s radical changes.

A) Pending: the FCA’s new UK-CCI rules

The Financial Conduct Authority (FCA) has long cited “widespread dissatisfaction” with the EU-PRIIPs and UCITS disclosure frameworks retained after Brexit. These are said to force firms “to explain their products using rigidly prescribed document templates”; the output contains “excessive amounts of information”, which are “unengaging and rely on legalistic financial jargon.” As a result, UK retail investors often find KIID/KID content “confusing or overwhelming, which can limit their ability to make effective decisions”. Moreover, “consumers do not usually read these documents.”

By contrast, the FCA’s new UK-CCI rules draw on consumer research and aim for firms to “design product information in ways that could be more engaging and understandable for consumers”. This bold, template-free retail disclosure regime will spring into action on April 6, 2026. The subsequent 14-month transition period will be uncharted territory for both EU and UK firms.

B) Main Elements

1. Product Summary Document

The “consumer-friendly” Product Summary Document (PSD) replaces both the UCITS KID and UK-PRIIPs KID for most retail investor products. The PSD must be “a short and concise document, setting out appropriate information about the essential characteristics” of the CCI, “conveying as a minimum the core information disclosures”. It must also contain “enough information …without relying on cross-references to other materials”.

The PSD has no prescribed template or fixed page count. However, depending on the specific product attributes and risk factors, it will need to include varying explanations, descriptions, and warnings. Unlike the PRIIPs KID and UCITS KIID, the PSD is considered a type of financial promotion, which can be used for financial promotions. However, it must be “clearly separate from other marketing materials.”

2. Core Product Information file

Both the UCITS-KIID and PRIIPs-KID are recognised as ‘standalone’ pre-contractual disclosures. Conversely, the CCI Product Summary document is based directly on an underlying, detailed ‘Core Product Information’ (CPI) file. The contents of the PSD “must reflect and be consistent with the underlying core product information”.

The CPI file also has no template. It is prepared in line with a limited set of detailed rules, designed “only to make sure key metrics are standardised and comparable across the products in scope”.

These relate to:

• General product information: Essential details to identify key facts about the investment (e.g., name, objectives, characteristics, any minimum holding period).
• Detailed product information: Calculated to common standards, covering: 

1. Risk & Returns: Including an overall score [1-10], based on standard deviation of returns calculated over 10 years; additional explanations, and risk warnings.
2. Costs & Charges: Specific disclosure of the OGC “headline figure”, one-off entry and exit costs, explicit Transaction Costs, with “concise, plain English descriptions of each figure.”
3. Performance: Monthly past performance information (depicted as a line graph), with prominent warnings.

3. UK CCI / Consumer Duty “Hybrid Approach”

To add to the complexity, the new UK-CCI regime is designed around the local Consumer Duty. The FCA says this “hybrid approach” enables firms to “focus on delivering good outcomes for their customers instead of prescriptive rules”. In practice, firms must take “reasonable care” to ensure their new CCI PSDs will “meet the information needs” of each investor, are “likely to be understood” and also facilitate “effective, timely and properly informed” decisions. The FCA recently published review findings on firms’ approaches to meeting their consumer understanding obligations. This contains examples of good and poor practice, “relevant to all regulated firms that provide products or services to retail customers”. Although ‘the Duty’ will continue to apply only to local Authorised Fund Managers (AFMs), the UK-CCI framework will impose similar “basic, high-level product governance standards” on ‘unauthorised’ EU-UCITS operators within the Overseas Funds Regime (OFR).

C) Roles and Responsibilities Pending

Manufacturers

Ongoing, product manufacturers are expected to:

• Provide both the PSD and a machine-readable CPI file to distributors “in good time” before the CCI is made available to retail investors.
• Publish both items on a public website.
• File their Product Summary Documents with the FCA*.
• Review and update all disclosed CCI information at least once every year.
• Respond to distributor feedback.

Firms must also pay attention to specific rules pertaining to Multi-option products, the use of representative share classes, and master/feeder funds.

NB: While only AFMs are mentioned in the CCI rules, EU-UCITS operators must also supply “consumer composite information documents” to the FCA [i.e., as OFR supporting documents].

Distributors

Product distributors will be obliged to:

• Provide the PSD to retail investors “at an appropriate stage in the investment journey”.
• Promote engagement with the key product information.
• Provide a copy of the PSD in a durable medium when investments are concluded.

The FCA also expects distributors to use the supplied CPI file to:

• “Familiarise” themselves with the information underpinning the CCI product summary.
• Provide additional product communications—such as explanations, illustrations, or other relevant information—to support investor understanding. This may include the use of layered information, graphics, and personalised cost/performance illustrations.

The Regulator

Starting from April 6, 2026, the FCA will “supervise and monitor” their new UK-CCI regime to gauge initial impact and “ensure it enables good consumer outcomes”, including:

• Readability of investment product information.
• Accessibility of product information in firms’ consumer journey.
• The success of their Consumer Duty ongoing work.
• Retail investors’ understanding of fund information, per the annual Financial Lives survey.

The FCA will also “keep under review” if firms require “additional guidance” to replace UCITS / PRIIPs Level 3 materials “that are no longer relevant due to the changes under CCIs”.

D) Next Steps: Transition Period

The CCI legislation comes into force on April 6, 2026. This triggers a 14-month transition period for both UK and non-UK firms, who can then choose to either:

• Produce a new CCI-Product Summary Document, or
• Continue to issue the UCITS KIIDs or UK-PRIIPS KIDs that currently apply to them.

The “full regime” will legally apply on June 8, 2027.

NB: The FCA clarifies, “the only part of the CCI regime that will turn on before June 8, 2027, is the [manufacturer’s] ability to produce and make available a product summary. Distributors’ obligations remain as just to provide the relevant disclosure document until June 8, 2027”.

E) Key Challenges and Open Questions

As the transition start date approaches, key practical complications include:

1. ‘Adapting’ Interlinked CCI Disclosures:
   One of the major CCI challenges facing manufacturers is their obligation to produce a PSD that accurately reflects the underlying CPI file (i.e. without any templates), including the specific need to adapt or summarise core content to provide retail investors with clear and understandable information.
    
2. Pending Consultations:
   The current Product Disclosure sourcebook (DISC) has been entirely rewritten by the CCI policy statement. However, the FCA has also confirmed it will hold three industry consultations in 2026 covering Consumer Duty rule changes, MiFID past performance presentation, and MiFID cost & charges disclosure rules. These may lead to further DISC changes before the end of the CCI transition period.
    
3. Industry Template Discontinuity:
   The current European PRIIPs templates (EPTs) reflect the EU and UK legal regimes in place since 2018. After the revocation of the UK-PRIIPs regime on April 6, 2026, the existing EPT V2.1 will not align with the new UK-CCI rules. A key question is whether the transition period will be sufficient to reshape the EPT, or if a new local template will be required. The European MiFID template [EMT V 4.2] will also require interim updates.
    
4. Sustainability information, links for EU-SFDR products:
   The CCI policy statement explains how disclosure rules align with the local Sustainability Disclosure Requirements (SDR), permitting UK firms to include SDR-related content in their PSDs. However, there is no mention of what information EU-SFDR article 8/9 products (within the OFR) can disclose.
    
5. Can Distributor rely on the PSD, only?:
   In due course, distributors must be able to reasonably rely on supplied CCI disclosure information to meet their Consumer Duty obligations. However, they are not due to receive a machine-readable CPI data file until June 6, 2027. Without a realigned EPT, they may only have access to the new “short, concise” Product Summary Document during the transition, which is a key concern.
    
6. Best Time for CCI Changeover:
   Many in the industry now favour February 19, 2027 (the deadline for the final UK-UCITS KIID update) to switch to the new PSD, thereby avoiding redundant output. However, others argue the earlier window could prove vital for reworking the EPT, agreeing on a standardised CPI file format, and completing revised EU/UK ‘dual disclosure’ processing.

How We Can Help

Clearstream provides a comprehensive UK CCI service to guide product manufacturers in meeting the FCA’s implementation deadline of June 8, 2027. Our fully managed service spans data ingestion, data validation, UK-specific calculations, template creation, document production, dissemination, and regulatory filing. Clearstream ensures full integration with other regulatory reporting services (PRIIPs, EMT/EPT, factsheets, ongoing charges, transaction cost calculations) to deliver a seamless and scalable operational model for clients active in the UK retail market.

To learn more about how Clearstream can help you prepare for the June 8, 2027 deadline, please contact us.


This article first appeared in Funds Europe on April 2, 2026.