The Financial Conduct Authority (FCA) published its final rules for the Consumer Composite Investments (CCI) framework on 8 December 2025, providing manufacturers with an 18-month implementation period before full enforcement. This marks the formal replacement of the UK UCITS KIIDs and UK PRIIPs KIDs, following an extensive consultation process that began in 2024.
Background and Scope of the New Regime
The CCI regime applies to any manufacturer or distributor of a Consumer Composite Investment offered to UK retail clients. Covered products include UCITS and non-UCITS funds, insurance-based investment products, structured products, and other composite or derivative-linked investments.
Under the new rules, manufacturers must produce a Product Summary together with a machine-readable core-information file, and make these available to distributors in good time before any retail sale.
The CCI regime becomes legally available on 6 April 2026, when the legislation commences. This marks the beginning of the transition window. Full, mandatory compliance for all in-scope products is required by 8 June 2027. This means manufacturers must have the compliant Product Summary and machine-readable file ready for distributors well in advance of the full compliance deadline to ensure uninterrupted retail distribution.
Key Technical Requirements and Enhancements in the Final Rules
Format Flexibility and Publication Options
Firms may present the Product Summary in PDF, web-based, or layered disclosure formats. While a printable version must remain available for retail clients, digital formats are permitted (including interactive or web-native versions), provided that all required information is included and clearly presented. The FCA removed the requirement for a rigid template, giving firms freedom to design disclosures in a consumer-centric way.
Machine-Readable File Requirement
Manufacturers are required to provide a machine-readable file containing the core product information (identifiers, strategy, objectives, costs, risk, performance, revision date, redress/complaints information, etc.) intended for use by distributors and other downstream parties. This supports data transparency, comparability, and smooth downstream distribution and reporting workflows.
The machine-readable file data challenge: The new regulatory requirement moves core product data from a human-readable document into a standardised, machine-consumable format. For most firms, this involves a complex data project to map, calculate, and format unique data points into the required schema. Our platform is engineered to automate this pipeline, instantly transforming your underlying product data into the compliant MRF structure with fully controlled data management and automatic dissemination.
Reformed Costs Disclosure
The new regime abandons the previously required inclusion of implicit transaction costs (such as slippage), addressing longstanding concerns about methodological inconsistency and misleading investor comparability. Instead, the “ongoing charges” figure becomes the headline cost metric. Explicit transaction costs and one-off costs must still be disclosed separately. Firms must categorise and present costs clearly, and may add explanatory narrative to support investor understanding.
Risk and Performance Information Requirements
Under the final rules, the risk indicator transitions from the previous PRIIPs/UCITS 1–7 formats to a new, more granular 1–10 scale, based on volatility or other appropriate risk/return modelling. This provides improved differentiation and retail understanding.
Firms must also provide a performance chart covering up to the last 10 years (or since inception, if the track record is shorter), including benchmark data when available. This helps provide context and comparability across products. Narrative explanations around performance are permitted — and encouraged — especially where the product’s history is limited, volatile, or requires additional clarity.
Optional Supplementary Content
Firms may include additional, non-mandatory content such as ESG metrics, benchmark comparisons, multilingual versions, and explanatory notes. These enhancements are not required but are encouraged where they help improve investor comprehension — giving firms the opportunity to tailor Product Summaries to their brand, investor base, and distribution channels.
Digital Publication: Moving Beyond the ‘Static’ PDF Trap
The FCA’s decision to permit web-based and layered disclosures is the biggest invitation for innovation in years. A static PDF, while compliant, risks failing the Consumer Duty’s requirement for clear, engaging communications. Firms can begin to adopt a modern, hybrid approach: a compliant, downloadable summary paired with an interactive, engaging digital version.
Our platform, iQuant Space, is purpose-built for this exact need. It enables structured publication of regulatory documents, supports automated, on-demand updates from underlying data feeds (crucial for maintaining a single, golden source of data), and delivers both public-facing access and secure MRF transfer to distributors. Using iQuant Space, firms can meet CCI requirements while providing a seamlessly engaging, navigable, and perpetually up-to-date disclosure experience that drives client comprehension and conversion.
Intersection with Consumer Duty: What Firms Should Keep in Mind
The CCI framework aligns with the broader aims of the UK Consumer Duty. While CCI sets out standardised content requirements for product disclosure, firms remain subject to the Duty’s principles: ensuring that communications, distribution strategies, and product governance deliver fair value and good outcomes for retail clients. That means firms should not treat the Product Summary as a standalone compliance exercise, but integrate it into their broader governance, value assessment, suitability analysis, and ongoing consumer-outcome monitoring processes as required under the Consumer Duty.
Next Steps
With the final rules now published, firms should begin:
- Mapping existing product data to the new CCI disclosure framework;
- Assessing data and operational readiness, particularly for the new 1-10 risk model and reformed cost data calculations;
- Selecting preferred presentation formats (PDF, web, hybrid) and design/layout approaches;
- Engaging with distributors to ensure timely delivery of core information and Product Summaries ahead of retail distribution;
- Reviewing product governance and Consumer Duty frameworks to embed the new disclosure regime holistically.
Don’t wait until 2027 to scramble for compliance. The CCI regime isn’t just a regulatory hurdle; it’s an opportunity to modernise investor communications. We are actively partnering with leading manufacturers, leveraging iQuant Space to transform static documents into dynamic, investor-forward digital experiences that meet the FCA’s standards and drive superior client engagement. Ready to turn compliance into your competitive advantage?
Contact us today to secure your design session and start building the future of disclosure.
The FCA’s publication may be accessed here.
