FCA to simplify investment disclosure regime: CP 26/24

Consumers need clear and relevant information to make better-informed choices.  This is particularly important for costs and charges disclosures, which help them to assess the value of products and services, and understand the effect of costs on returns. In CP 26/24 on Simplifying Consumer Investment Disclosures, published on July 2, 2026, the FCA is looking at this very point.  The CP lands at the same time as an FCA review into how well pre-sale investment disclosure documents work for consumers – which indicates that current pre-sale investment disclosure documents are too difficult to read and understand for most consumers.  The FCA’s proposals are to align the cost disclosure requirements which derive from MiFID with the FCA’s new CCI regime.  Specifically the FCA propose changes to:

• further align the rules in COBS with our new CCI regime and to make cost disclosures more consistent throughout the investment journey. The FCA’s aim is to ensure that the pre-sale presentation of product costs under its rules in COBS aligns with the disclosure framework for CCIs.

• remove the MiFID-derived cumulative effect illustration pre-sale and post-sale and instead require firms to show how costs have impacted returns in regular post-sale reporting.

• allow firms to use CCI cost categories in their regular post-sale reporting while maintaining the requirement for consumers to be told the total costs they have paid in pounds and pence.

• remove most prescriptive requirements for business with professional clients while retaining obligations on firms to provide them with transparent cost disclosures and other core information.

• embed FCA expectations that consumers are clearly told about the interest rates they will receive on their cash balances or any fees they pay on cash held in investment accounts. Firms should explain in a consumer-friendly way how they set the interest rate consumers will receive on their cash. The FCA is also codifying a requirement that firms do not both charge fees and retain interest on cash holdings (double dipping) as set out previously in its 2023 Dear CEO letter.

• simplify and streamline rules for MiFID, IDD, and non-MiFID business to reduce burden on firms and ensure a more consistent consumer experience. There is recognition that the co-existence of three similar but distinct regimes increases complexity.

The Consumer Duty is clearly front and centre in the FCA’s mind here - with the FCA looking to apply the same Duty-driven approach that it has employed under the CCI regime, focusing on consumer engagement and understanding. This aligns well with the FCA’s stated ambition to modernise disclosures through its Consumer Duty Requirements Review - as a part of which the FCA is seeking opportunities to streamline disclosure requirements to promote, where appropriate, greater consistency in disclosure standards whilst taking advantage of the Duty’s higher standards and additional flexibility.  Whilst this is a positive change on paper – with the focus shifting away from prescriptive standards and towards a framework that instead focuses on consumers outcomes - firms will need to give thought to how compliance can be evidenced (more of a challenge where one can no longer point to a template disclosure).  This is something to watch as the consultation unfolds

The consultation closes on 21 August 2026, after which a Policy Statement with final rules is expected before the end of 2026.