On 8 December, the FCA has published PS25/20 setting final rules for the UK’s new Consumer Composite Investments (CCI) disclosure framework, replacing the PRIIPs KID and UCITS KIID with a more flexible and less prescriptive regime. This follows on from CP24/30 and CP25/9 (see our previous client note here), The rules standardise core metrics while allowing firms freedom in form and presentation to improve consumer engagement, and are explicitly underpinned by the Consumer Duty.
Scope, who is in, and timing
The scope of the regime is fundamentally determined by legislation (The Consumer Composite Investments (Designated Activities) Regulations 2024), and applies across a broad set of packaged retail investments including open‑ended and closed‑ended funds, IBIPs, structured products and deposits, CFDs and other complex products.
The FCA has simplified non‑retail carve‑outs: manufacturers can stay out of the new DISC rules by clearly marking communications as not for retail and ensuring an appropriate distribution strategy. Notably, the previously proposed minimum investment threshold is removed.
The FCA confirms an 18‑month implementation period for all products. The regime commences 6 April 2026 with an optional transition period during which manufacturers may produce either a CCI product summary or maintain existing disclosure. Full go‑live is 8 June 2027.
The CCI “product summary” and information architecture
Manufacturers must produce a concise, consumer‑friendly product summary containing standardised core information on costs, risk and return, and past performance, supported by underlying machine‑readable data for distributors. The FCA has deliberately avoided templating and page limits to enable innovation, while maintaining standardisation in some areas where it aids comparability.
Distributors must make the product summary available pre‑sale, highlight key items to support a timely and properly informed decision, and provide the product summary in a durable medium post‑sale. Pre‑sale, distributors must at minimum surface: a brief product explanation, the ongoing costs figure and other relevant costs, the risk and return score and a short explanation including any required warnings.
Underlying product information must be provided by manufacturers in a machine‑readable file, but an exemption applies where the manufacturer is the only distributor of its products.
Key updates since consultation
- Manufacturer vs distributor responsibilities: Respondents opposed allowing distributors to create or amend product summaries. The FCA rules now make manufacturers solely responsible for the product summary, which distributors must deliver it unamended post‑sale, but may tailor how they highlight information pre‑sale.
- Scope clarifications and non‑retail opt‑out: The FCA has clarified that “plain vanilla listed bonds” and certain IBOR‑linked bonds are out of scope, and removed the minimum investment limb from the non‑retail criteria, allowing manufacturers to take products out of DISC through labelling and distribution controls. The FCA has also confirmed that closed-ended investment funds (CEIFs) are in-scope.
- Costs and charges presentation: The headline figure is now the Ongoing Costs Figure (OCF), in percentage and pounds‑and‑pence terms. One‑off and explicit transaction costs must be disclosed clearly but are not aggregated into the OCF (to avoid the implication that they are payable every 12 months). Implicit transaction costs (e.g., bid‑ask spread) are not required (per CP25/9 proposals) but note that mark-ups and mark-downs are explicit costs in their view. Where costs are zero, firms need not display the category in the summary (but must confirm zero in the underlying file).
- Pull‑through of underlying costs: The FCA has refined its approach. Costs of underlying open‑ended funds and ETFs continue to be pulled through into a synthetic OCF. For CEIFs held by a CCI, their costs must be disclosed transparently but are not added to the investing fund’s OCF. Instead, a weighted average cost‑to‑NAV ratio must be calculated and presented. The proposed passive‑fund exemption from pull‑through is dropped.
- Gearing and maintenance costs: Gearing and real‑asset maintenance costs are excluded from the OCF across all CCIs (now the FCA has extended an original proposal for CEIFs to all CCIs).
- Structured products: Responding to feedback on structured products, the FCA has clarified that where a product’s maturity date is less than one year, costs should be shown over the lifetime of the product.
- Risk and return: The metric originally entitled “risk score” has been retitled a “risk and return” score to support balanced messaging. The FCA has extended the volatility lookback from 5 to 10 years, which firms must simulate where needed. The FCA has adjusted their rules so that products with low liquidity are no longer given an automatic “9”, instead, products with illiquid assets or limited access must add at least +1 to the score unless already at 9. Structured products must use a VEV methodology to calculate volatility, and SCARPs are no longer automatically 9 but require a complexity label.
- Past performance: The graph now requires monthly data points, not quarterly and labels can reflect non‑calendar rolling periods. Pre‑merger track‑record inclusion is dropped. The FCA has also clarified rules around benchmark comparisons where a product’s objectives and strategy have changed.
- MiFID costs disclosures: The FCA has transposed MiFID Org Reg Article 50 into the Handbook without substantive change to aggregation or “cumulative effect” expectations. A wider MiFID review will follow in 2026.
- Co‑operation and Duty alignment: Information‑sharing duties across the chain are retained but reframed as proportionate and aligned with the Consumer Duty, with additional consultation on Duty application in distribution chains is planned for H1 2026.
Practical implications and next steps for firms
Taken together, the final CCI rules and move away from PRIIPs KIDs and UCITS KIIDs materially shift the UK disclosure regime from revolving around prescriptive form to outcomes. Firms will have significant discretion in design and layering, but that flexibility is paired with precise, comparable metrics on costs, risk and performance. This new discretion, while welcome, will require firms to make their own judgment calls about many aspects of disclosure. This will require robust documentation of methodologies and judgments.
Firms involved in retail products in the UK will need to finalise their scoping exercises to understand where they need to comply with the new regime. Where firms are seeking to avoid the application of the regime by relying on the non-retail products exemption, they need to evaluate their approach to these products and ensure the appropriate disclosures and controls are in place to prevent retail distribution.
Manufacturers should initiate product analyses against DISC to design product summaries and support machine‑readable data sets, including methodologies for OCF, explicit transaction costs, and, where relevant, pull‑through measures and non-OCF cost transparency.
Distributors should plan consumer‑journey changes to align with the new rules, and build ingestion of manufacturer machine‑readable files, define reliance checks for manufacturer content, and design Consumer Duty‑aligned layering and contextualisation.
Programme planning should align to the optional transition from April 2026 and full go‑live by 8 June 2027. A practical approach may be to focus on ensuring new products are aligned with the regime from April 2026 (to avoid recalibrating compliance very soon after launch).
