UK fund disclosure overhaul: what the CCI regime means

UK fund disclosure overhaul: what the CCI regime means

For more than a decade, UK retail investment products have carried one of two disclosure documents: the UCITS Key Investor Information Document (KIID) or the PRIIPs Key Information Document (KID).

Zeidler recently delved into  the regulations and changes to the UK market. They were designed to give investors standardised, comparable information, but the Financial Conduct Authority (FCA) has now concluded, following extensive behavioural research, that the goal was never fully met. Many consumers simply didn’t engage with the paperwork, and those who did often found it hard to follow or of little practical use.

Zeidler notes that the Consumer Composite Investments (CCI) regime, confirmed in the FCA’s final rules under PS25/20, is designed to fix that. It scraps the UCITS KIID and UK PRIIPs KID in favour of a single new document: the Product Summary.

According to Zeidler, the real shift isn’t cosmetic. Unlike its predecessors, the Product Summary has no prescribed template. The FCA still standardises the underlying methodologies, a new 1-10 risk and return score based on ten years of volatility data, a past-performance graph modelling a £10,000 investment, and cost disclosures split across five categories, but layout, tone, length and design are left entirely to manufacturers. That freedom sits inside the Consumer Duty framework, meaning firms must prove their format genuinely supports consumer understanding, with the FCA planning to supervise readability once the regime goes live.

Zeidler points out that scope is broad, covering UCITS funds, investment trusts, structured products, structured deposits, insurance-based investment products, derivatives, contracts for difference and contingent convertible securities. Crucially, it applies wherever a product is marketed to UK retail investors, regardless of where the manufacturer sits, meaning an Irish or Luxembourg UCITS needs a UK Product Summary just like a domestic fund. For cross-border managers still bound by the EU’s unchanged PRIIPs KID, that means running two distinct disclosure regimes in parallel.

The timeline, Zeidler explains, gives firms room but not much. Voluntary adoption opened on 6 April 2026, running alongside existing documents until the regime becomes mandatory on 8 June 2027, after which KIIDs and KIDs will no longer satisfy UK requirements.

Zeidler’s advice for this quarter is to focus on three areas: mapping every in-scope product and share class, auditing current data against new requirements, and comparing existing PRIIPs calculations with CCI methodologies. Firms that start now, Zeidler argues, will have time to test disclosures with consumers and embed new processes, while those waiting until 2027 risk tackling calculation changes, redesign and distributor demands all at once.

For more, read the full story here. 

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