FCA Consumer Composite Investments (CCI) Final Rules: Your 18-Month Implementation Roadmap

The Financial Conduct Authority has today published Policy Statement PS25/20, introducing the final rules for the Consumer Composite Investments (CCI) regime. This represents the most significant overhaul of retail investment product disclosure in over a decade, replacing the existing PRIIPs Key Information Document (KID) and UCITS Key Investor Information Document (KIID) framework with a more flexible, consumer-focused approach.

For firms manufacturing or distributing investment products to UK retail clients, the clock is now ticking on an 18-month implementation period. Whilst the new regime offers optional early adoption from 6 April 2026, compliance becomes mandatory from 8 June 2027.

This guide explains what the CCI regime means for your firm and provides a practical roadmap for achieving compliance within the FCA's timeline.

What Are Consumer Composite Investments?

Consumer Composite Investments is the FCA's new regulatory framework for disclosure requirements applicable to packaged retail investment products. The regime covers:

Collective investment schemes (including UCITS funds and non-UCITS retail schemes)
Insurance-based investment products (IBIPs), such as investment bonds and unit-linked life insurance
Structured products and structured deposits
Retail deposits with investment-like features
Contracts for difference (CFDs) offered to retail clients

In essence, if your firm manufactures or distributes any product that pools or packages an investment for retail consumers, it likely falls within scope of the CCI regime.

Why Is the FCA Replacing PRIIPs?

The PRIIPs KID regime, introduced in 2018 following the EU's Packaged Retail and Insurance-based Investment Products Regulation, has been widely criticised for producing disclosure documents that are difficult for consumers to understand and expensive for firms to produce.

Key problems with the PRIIPs framework included:

Overly prescriptive presentation requirements that limited firms' ability to explain products clearly
Complex performance scenario calculations that confused rather than clarified
Rigid cost disclosure formats that didn't align with how consumers make decisions
Lack of machine-readable data, creating inefficiencies for distributors and platforms

The FCA's CCI regime addresses these shortcomings by adopting a more principles-based approach that prioritises consumer understanding whilst maintaining consistent standards across different product types.

Key Features of the CCI Regime

1. Consumer-Friendly Product Summaries

Manufacturers must produce clear, concise product summaries designed to help consumers understand what they're buying. Unlike PRIIPs KIDs, the CCI framework provides firms with greater flexibility in how they present information, provided the content meets regulatory standards for clarity, fairness, and completeness.

The product summary must include standardised sections covering:

Product objectives and investment strategy
Risk and return characteristics
Costs and charges
Past performance (where applicable)
Practical information (such as how to buy, sell, or switch)

2. Enhanced Risk Disclosure Requirements

The CCI rules introduce stricter risk disclosure standards, particularly around liquidity risk. Where a product has limited liquidity or restrictions on redemptions, firms must increase the product's risk score by at least one level on the standardised risk scale.

This requirement directly addresses concerns raised under Consumer Duty about products where consumers could not easily access their money when needed. Firms will need to carefully assess their products' liquidity characteristics and ensure risk ratings accurately reflect this dimension.

3. Standardised Costs and Charges Disclosure

Whilst maintaining the PRIIPs principle of showing total costs as a percentage and monetary amount, the CCI regime provides greater flexibility in how ongoing costs are presented. Firms can tailor cost illustrations to reflect how consumers typically invest in their products, making the information more relevant and meaningful.

Transaction costs, portfolio turnover costs, and performance fees must all be disclosed in a standardised format, enabling consumers to compare costs across different products and providers.

4. Structured Products: VEV Methodology Required

For structured products, the FCA mandates use of the "Value for Evaluation Variable" (VEV) model for calculating and presenting performance scenarios and risk indicators. This methodology provides a more robust and consistent approach than the previous framework, though it will require significant systems and process changes for many manufacturers.

5. Machine-Readable Data for Distributors

One of the most significant operational changes is the requirement for manufacturers to provide product information in a machine-readable format. This enables distributors, platforms, and advisers to efficiently access, update, and display product information within their systems.

The FCA will specify the required data standards and formats, which firms must implement ahead of the mandatory go-live date. This requirement aims to reduce operational friction, lower costs, and improve the accuracy of information provided to consumers across distribution channels.

What This Means for Your Firm

The impact of the CCI regime depends on your firm's role in the product lifecycle:

For Product Manufacturers

As a manufacturer, you bear primary responsibility for producing compliant CCI product summaries and machine-readable data. Your key obligations include:

Comprehensive product review: Assess your entire product range to identify which products fall within the CCI regime scope
Risk rating methodology: Develop or update your approach to risk rating, ensuring liquidity constraints are properly reflected
Content creation: Draft new product summaries that meet CCI requirements whilst effectively communicating product features
Data infrastructure: Implement systems capable of generating and maintaining machine-readable product data
Governance and oversight: Establish processes for reviewing and updating CCI disclosures as products evolve

For Distributors and Platforms

Distributors must ensure they provide consumers with the manufacturer's CCI product summary before or at the point of sale. Your responsibilities include:

Systems integration: Update your technology infrastructure to receive, store, and display machine-readable product data
Due diligence processes: Verify that manufacturers are providing compliant CCI documentation for products you distribute
Sales processes: Ensure front-line staff and digital journeys incorporate CCI product summaries at appropriate points
Record-keeping: Maintain evidence that consumers received required disclosures

For Firms in Both Roles

If your firm both manufactures and distributes products, you'll need to address requirements from both perspectives. Particular attention should be paid to internal handoffs between product management and distribution teams to ensure seamless compliance.

Your 18-Month Implementation Roadmap

With mandatory compliance required by 8 June 2027, firms should adopt a phased approach to implementation:

Phase 1: Assessment and Planning (Months 1-3)

December 2025 - February 2026

Conduct a comprehensive product inventory to identify in-scope CCIs
Assess current disclosure documentation against CCI requirements
Identify gaps in content, format, and data capabilities
Establish a cross-functional project team (product, legal, compliance, technology, operations)
Develop a detailed implementation plan with clear milestones and ownership
Allocate budget for systems development, content creation, and external support if needed

Phase 2: Systems and Infrastructure (Months 4-9)

March 2026 - September 2026

Design and build capability to produce machine-readable data in FCA-specified formats
Integrate data feeds into distribution systems and platforms
Develop templates and style guides for CCI product summaries
Build or enhance risk rating methodologies, incorporating liquidity adjustments
For structured product manufacturers: implement VEV model calculations
Test data flows between manufacturer and distributor systems

Phase 3: Content Development (Months 10-15)

October 2026 - March 2027

Draft CCI product summaries for all in-scope products
Conduct consumer testing to ensure documents are clear and understandable
Review and approve content through governance processes
Translate technical product features into plain language explanations
Ensure consistency across product ranges whilst respecting individual product characteristics
Prepare supporting materials for sales teams and intermediaries

Phase 4: Testing and Readiness (Months 16-18)

April 2027 - June 2027

Conduct end-to-end testing of systems, processes, and content
Run parallel operations with existing PRIIPs/KIID documentation
Train staff across product, compliance, and distribution functions
Perform final quality assurance checks on all CCI documentation
Establish ongoing monitoring and review processes
Prepare for go-live on 8 June 2027

Early Adoption Option (From 6 April 2026)

Firms that wish to adopt the CCI regime early can begin using the new framework from 6 April 2026. Early adoption may be advantageous for firms with:

Limited product ranges that can be migrated quickly
Consumer feedback indicating problems with current PRIIPs KIDs
Strategic reasons to differentiate through clearer disclosure
Systems refresh projects already underway

However, early adoption requires full compliance with all CCI requirements and cannot be applied selectively to some products whilst maintaining PRIIPs KIDs for others within the same product category.

Interaction with Consumer Duty

The CCI regime sits alongside and reinforces the Consumer Duty, which requires firms to act to deliver good outcomes for retail customers. The principles underlying CCI—clarity, comparability, and consumer understanding—directly support Consumer Duty objectives.

Firms should consider CCI implementation as part of their broader Consumer Duty compliance programme, ensuring:

Product summaries genuinely help consumers make informed decisions
Risk ratings and cost disclosures are fair and not misleading
Distribution arrangements ensure target customers receive appropriate products
Regular reviews assess whether CCI documentation continues to meet consumer needs

Key Risks and Challenges

Firms should be alert to potential implementation challenges:

Tight timelines: Eighteen months may sound generous, but systems development, content creation, and testing consume time quickly. Start planning immediately.

Technology complexity: Machine-readable data requirements demand significant technical capability. Engage your technology teams early and consider whether existing systems can be enhanced or require replacement.

Resource constraints: Implementation will compete with other regulatory priorities. Secure executive sponsorship and adequate resources.

Cross-border considerations: Firms operating in multiple jurisdictions must navigate the interaction between UK CCI requirements and EU PRIIPs rules for products distributed internationally.

Third-party dependencies: Manufacturers rely on distributors having compatible systems; distributors depend on manufacturers providing quality data. Early dialogue between parties is essential.

How MEMA Consultants Can Help

As specialist FCA compliance consultants, MEMA supports firms throughout the CCI implementation journey:

Gap analysis and project planning: We assess your current state and develop a tailored implementation roadmap
Risk rating methodology: We help design and validate compliant approaches to product risk assessment
Content development: Our regulatory communications specialists draft clear, compliant product summaries
Systems requirements: We define functional and technical requirements for CCI data capabilities
Governance and oversight: We establish appropriate frameworks for ongoing CCI compliance
Training and embedding: We equip your teams with knowledge and tools to sustain compliance

Our consultants combine deep regulatory expertise with practical implementation experience, helping you navigate the CCI regime efficiently whilst maintaining focus on business-as-usual activities.

Conclusion

The Consumer Composite Investments regime represents a fundamental shift in how retail investment products are disclosed to UK consumers. Whilst the principles-based approach offers welcome flexibility compared to PRIIPs, achieving compliance demands careful planning, significant investment, and sustained effort across multiple functions.

With the mandatory deadline of 8 June 2027 now fixed, firms should begin implementation immediately. Those that treat CCI as a compliance exercise alone miss an opportunity: well-executed product summaries can differentiate your products, build consumer trust, and demonstrate commitment to delivering good outcomes under Consumer Duty.

The next 18 months will test firms' ability to translate regulatory requirements into operational reality. Success requires clear strategy, adequate resources, and expert guidance.

Need support with CCI implementation? MEMA Consultants' regulatory specialists are ready to help you navigate the new regime. Contact us today to discuss your requirements and how we can support your compliance journey.

About MEMA Consultants: We are a specialist UK FCA compliance consultancy providing expert regulatory advice, implementation support, and ongoing compliance services to financial services firms. Our team combines technical regulatory knowledge with practical industry experience to deliver pragmatic, effective solutions.