Consumer Composite Investments (CCI): The FCA's Replacement for PRIIPs

After nearly a decade of complaints from asset managers and advisers that the PRIIPs KID actively confused retail investors rather than helping them, the FCA is finally replacing it. The new Consumer Composite Investments (CCI) regime brings UK retail investment disclosure into a single, more flexible framework — and firms have a defined transition window to get ready.

What CCI replaces

The CCI regime eliminates two overlapping UK disclosure frameworks in one move: the PRIIPs Key Information Document (KID), inherited from EU law and widely criticised for its rigid, sometimes misleading performance scenarios, and the UCITS Key Investor Information Document (KIID), the older fund-specific disclosure format. Both are replaced by a single "CCI product summary" requirement, closing a long-standing quirk where broadly similar investment products were subject to two different disclosure regimes depending on their legal structure.

The implementation timeline

The FCA has structured the transition in two phases:

• 6 April 2026 — an optional transition period opens. Firms may adopt the new CCI rules early, or continue operating under existing PRIIPs/UCITS disclosure requirements.
• 8 June 2027 — mandatory compliance deadline. From this date, all in-scope firms must have fully transitioned to the CCI regime; the old PRIIPs KID and UCITS KIID formats can no longer be used.

The 14-month optional window is a deliberate design choice, letting firms manage the systems and documentation changes on their own timeline rather than facing a single cliff-edge switchover.

What's different about the new disclosure

Rather than prescribing an almost rigid, form-filling format the way PRIIPs did, the CCI regime shifts toward principles-based flexibility while still standardising the core numbers that matter for comparison. The new product summary must include:

• Investment objectives and policy, in plain language
• A risk/return indicator using a standardised 1-10 risk scale
• Historical performance information
• Costs and charges, presented in a standardised way
• Product identification and issuer information
• A requirement for annual review and update

The intent is a genuinely "consumer friendly" document rather than one optimised for regulatory box-ticking — while keeping the risk, cost and performance calculation methodologies standardised enough that products remain comparable across providers.

Manufacturer and distributor responsibilities

The regime splits obligations clearly between two roles. Manufacturers — the firms creating the investment product — must prepare and publish the CCI product summary on an accessible website, alongside machine-readable underlying data, before the product is distributed to retail investors. Distributors, meanwhile, must provide the unamended summary to investors in a durable format at the point of sale, highlighting the key information without creating their own competing disclosure documents. This division is intended to stop the drift that happened under PRIIPs, where distributors sometimes layered additional, inconsistent materials on top of the manufacturer's KID.

What firms need to do to prepare

• Identify which products in the current range will be classified as CCIs under the new regime, since scope isn't identical to the old PRIIPs/UCITS boundary in every case
• Determine whether the firm is acting as manufacturer, distributor, or both, for each relevant product
• Build or adapt systems to produce the new-format product summaries, including the machine-readable data requirement for manufacturers
• Embed Consumer Duty considerations into the disclosure review process, since the FCA has been explicit that CCI compliance sits alongside, not instead of, existing Consumer Duty obligations
• UK firms distributing to, or marketing from, overseas should also check financial promotion requirements for unauthorised or overseas manufacturers

Why this matters beyond compliance teams

For finance professionals advising asset managers, platforms or distributors, CCI is a genuine product and operations change, not just a legal drafting exercise — it affects how performance and cost data flows from portfolio and finance systems into a public-facing document with a hard compliance deadline. It's also a useful example, alongside reforms like the move to T+1 settlement, of how much post-Brexit UK financial regulation is now diverging from, rather than simply mirroring, the equivalent EU rules.

FAQ

Do firms have to switch to CCI immediately?
No — the transition period from 6 April 2026 is optional. Firms can continue using PRIIPs/UCITS disclosures until the mandatory deadline of 8 June 2027.

Does CCI apply to EU-domiciled funds sold in the UK?
CCI is a UK-specific regime, replacing the UK's retained PRIIPs framework. Funds distributed in both the UK and EU will need to consider both the UK CCI rules and the EU's own (unchanged) PRIIPs regime separately.

Who is responsible for producing the CCI product summary?
The manufacturer of the investment product — the distributor's role is to pass on the summary unamended at the point of sale, not to produce their own version.

Retail disclosure reform is a good example of how UK financial regulation is quietly diverging from its EU-derived origins post-Brexit. Learnsignal's CPD courses track exactly this kind of regulatory change across investment, risk and compliance topics.

The long-running case against PRIIPs

It's worth understanding why the FCA felt compelled to replace PRIIPs rather than simply amend it. The regime's headline complaint centred on its "future performance scenarios" — projections that, in periods of low interest rates and unusual market conditions, sometimes produced results widely seen as actively misleading rather than merely imprecise. Consumer groups, asset managers and even regulators themselves flagged repeatedly that the format optimised for regulatory consistency at the expense of genuinely helping ordinary investors compare products. CCI's more principles-based approach to the underlying narrative content, while keeping core numbers standardised, is a direct response to that decade of criticism.