The FCA finalises the CCI disclosure framework – our initial takeaways.

On 8 December, the FCA published PS 25/20, setting out the rules for its new Consumer Composite Investment (“CCI”) regime. This will replace the prescriptive PRIIPs and UCITS disclosure frameworks with a single, more qualitative and UK-tailored regime for products where returns depend on underlying or reference assets. The Policy Statement follows consultations in December 2024 and April 2025. For additional background on the FCA’s proposed regime, please see our earlier notes on the consultation papers: here and here.

What’s changed from the consultation?

The FCA has made a number of important refinements to its disclosure regime for CCIs. We have summarised some of the headline changes below:

• Manufacturers will have sole responsibility for preparing and maintaining product summaries; distributors are to provide these to clients unamended, but must promptly raise and share concerns where any disclosure may be misleading, inaccurate or out of date. Information sharing obligations across the distribution chain are intended to be proportionate and Consumer Duty aligned.
• The scope of the new regime has been refined: “plain vanilla” listed bonds are expressly out of scope; products clearly marked “not for retail” and with a non‑retail distribution strategy fall outside the rules; closed ended investment funds are confirmed to be in scope.
• The envisaged “risk score” has been replaced with a “risk and return” metric based on 10 years of standard deviation data, supplemented by a short narrative; products with liquidity constraints must add at least one point to the calculated score (unless already at nine).
• Past performance disclosures must now use monthly (rather than quarterly) data points to provide a more granular and informative performance history.
• Cost and charges disclosures have been reshaped around a single “ongoing costs figure” (OCF) shown as both a percentage and an amount, with one off and explicit transaction costs disclosed separately and implicit transaction costs no longer required to be disclosed.

In terms of timing, the FCA has set an 18‑month implementation period for all products. The new regime applies from 6 April 2026, from which point manufacturers can either use the new CCI product summaries or retain their current (i.e. UK PRIIPS/UCITS) disclosures. The use of CCI-compliant product summaries becomes mandatory from 8 June 2027.