The United Kingdom has launched a sweeping new disclosure framework for investment products sold to retail investors, marking a significant post-Brexit regulatory shift.
The Consumer Composite Investments regime, which took effect on 6 April 2026, replaces the existing PRIIPs KID and UCITS KIID disclosure documents with a new standardised Product Summary.
Product manufacturers have until 7 June 2027 to replace their current retail product disclosures with a compliant CCI Product Summary under the new rules.
The regime applies to any firm manufacturing, advising on, offering, or selling a CCI to a retail investor in the United Kingdom, regardless of where that firm is based.
Crucially, the new framework extends the Financial Conduct Authority’s regulatory perimeter to include firms carrying on certain designated activities involving CCIs, even if those firms are not FCA-authorised.
This means overseas firms, including EU UCITS management companies distributing funds to UK retail investors, may be subject to the new requirements.
The CCI framework was established by the Consumer Composite Investments (Designated Activities) Regulations 2024, which granted the FCA new rule-making powers in this area.
A CCI is broadly defined as an investment where returns are dependent on the performance of, or changes in, the value of underlying or reference assets, covering funds, structured products, contracts for difference, and insurance-based investment products.
Certain products are expressly excluded from the CCI definition, including plain vanilla listed bonds, equity shares in commercial companies, pure protection life insurance, standard deposits, and pension schemes.
The new Product Summary must include general product information, costs and charges, a risk-and-return score, and ten years of past performance presented in a line graph format.
Unlike the previous UCITS KIID or PRIIPs KID, the format of the Product Summary is not prescribed and there is no fixed template, though some elements retain standardisation to facilitate product comparisons.
Risk must be expressed using a numbered scale from 1 to 10, calculated using the standard deviation of returns over a ten-year period, with structured products using a value-at-risk method instead.
Costs must be disclosed showing gross charges in relation to an assumed investment of £10,000, covering ongoing costs, entry costs, exit costs, transaction costs, and any performance fees or carried interest.
Manufacturers must also produce a Core Information Disclosure, provided to distributors in a machine-readable format, covering the same four categories as the Product Summary.
FinDatEx has announced it has commenced a targeted review of the European MiFID Template and European PRIIPs Template focusing on CCI-specific changes, aiming to publish revised versions in early 2027.
The FCA has acknowledged a discrepancy between CCI cost disclosures and existing MiFID-derived requirements, proposing alignment changes in Consultation Paper CP26/24, with final rules expected by end of 2026.
Most firms are expected to transition to Product Summaries at the time of their next annual UCITS KIID update in the first quarter of 2027, making early preparation essential.
Manufacturers should not assume that narrative descriptions from existing PRIIPs KIDs or UCITS KIIDs can simply be carried across into the new Product Summaries without review or consumer testing.
Firms should begin immediately by identifying all in-scope products, developing compliant Product Summary templates, and ensuring they have the data and processes needed to calculate the required performance and risk indicators.