From EU UCITS KIID & EU PRIIPs KID To the UK Consumer Composite Investments (CCI) Product Summary:
Introduction
The UK retail disclosure framework is undergoing a structural change. Under the new regime, Consumer Composite Investments (CCIs) replace the former PRIIPs framework, and the new Product Summary replaces the former UCITS KIID and PRIIPS KID disclosure regimes for products offered to UK retail investors.
This shift reflects a broader regulatory objective: to improve consumer understanding while aligning disclosures with the UK Consumer Duty.
This article explains what CCIs are, which entities and products fall within scope, which disclosures are required, and how the new Product Summary and underlying information differ from previous frameworks.
From PRIIPs to Consumer Composite Investments (CCI)
What Is a Consumer Composite Investment?
A Consumer Composite Investment (CCI) is the new term used in the UK regime to describe products previously classified as PRIIPs.
A CCI is defined as a product in which the returns received by the investor depend on the performance of indirect investments, such as underlying or reference assets. This definition aligns with existing legislation and ensures continuity with the former PRIIPs and UCITS regimes.
Under the new framework:
- The regime is established directly under UK legislation
- Disclosures are framed within the principles of the Consumer Duty
- The PRIIPs KID and UCITS KIID are replaced by a Product Summary
What Is a Product Summary?
The CCI regime is underpinned by the Consumer Duty, with the final rules set out in FCA Policy Statement PS25/20, published on 8 December 2025.
What Is Flexible
Manufacturers are granted broad flexibility in how they design Product Summaries, including flexibility regarding:
- Structure and layout
- Use of explanatory narratives
- Supplementary contextual information
This flexibility is intended to improve clarity and consumer understanding.
What Is Strictly Required
Despite the flexibility in presentation, certain elements are fully standardized and mandatory, including:
- Core information on some costs, risks, returns, and past performance
- Uniform calculation methodologies
- Prescribed presentation standards for quantitative data
Manufacturers may not alter the substance of the core information.
Entities and Products in Scope
Entities in Scope
Any firm engaged in designated activities under the Designated Activities Regime (DAR) introduced by FSMA 2023 falls within scope, regardless of authorization status.
Designated activities include:
- Manufacturing a CCI
- Advising on a CCI
- Offering a CCI to UK retail investors
Both authorized and unauthorized manufacturers are included.
Products in Scope
The CCI regime applies to all products offered to UK retail investors, including:
- Open-Ended Investment Funds (OEIF)
- Closed-Ended Investment Funds (CEIF)
- Overseas funds marketed to UK retail investors
- Structured products and structured deposits
- Contracts for Difference (CFDs)
- Insurance-Based Investment Products (IBIPs)
- Other complex products, including derivatives
Products Out of Scope
Products not intended for the retail market are excluded from the CCI regime, including:
- Authorized Contractual Schemes (ACS)
- Qualified Investor Schemes (QIS)
Timelines and Application Dates
Key milestones include:
- December 2025: FCA publishes final rules
- 6 April 2026: CCI legislation enters into force
- 6 April 2026 – 7 June 2027: Transitional period starts
During this period, firms may use:- A Product Summary
- An EU PRIIPs KID
- A UK PRIIPs KID
- An EU UCITS KIID
(provided DISC TP 2.11R conditions are met)
- From 8 June 2027: Mandatory application of the product summary
New Disclosure Documents Replacing UCITS KIID and PRIIPs KID
Manufacturers of CCIs must provide two distinct types of disclosure documents.
Core Information Disclosures to Distributors
This document contains all the elements and data required to support the understanding of the Product Summary.
Intended recipient: Distributors
Format: Machine-readable file (e.g. CSV)
Publication:
- Normally communicated to distributors
- Also required to be available on a publicly accessible website
Product Summary (Equivalent to the PRIIPs KID / UCITS KIID)
The Product Summary must be provided to the retail investor before the purchase of the CCI.
The Product Summary provides:
- General product information
- Key information on costs, risks, returns, and past performance
- Calculations based on standardized methodologies
Key characteristics:
Distributors have freedom in the design, delivery, and additional content, provided the core information is not altered.
Intended recipient: Consumers (via distributors)
Format: PDF
Publication: Publicly accessible website
Product Summary content
General Product Information
The Product Summary must include clear general product information enabling investors to identify the product, understand its key characteristics, and access relevant protections. This includes, among others, the fund name, ISIN or unique product identifier, manufacturer’s legal name, the date of preparation or last update, the type of investment, objectives and strategy, how investors can submit complaints.
In short, it should include all information necessary to enable an investor to understand the nature and principal features of the product.
Risk and Return Score (RRS)
RRS Ranking
- Scale: 1 to 10
- Based on annualized volatility intervals
- Calculated using:
- Standard deviation of past performance
- Ten consecutive years of data
- Data ending within 60 days before preparation or update
RRS Adjustments
- Adjustments are permitted at the manufacturer’s discretion but must be justifiable
- Specific adjustment rules of this score are given by the regulation (Depending on the CCI type and the assets in which it invests)
Costs and Charges Disclosure
Costs are disclosed:
- In pounds and pence (with FX rate where relevant)
- On an assumed investment amount
- Using prescribed look-back periods
Key principles include:
- One-off costs (entry/exit)
- Ongoing costs (direct and indirect)
- Transaction costs (explicit only)
- Zero-cost items disclosed to distributors via core information, but not shown in the Product Summary
- Additional disclosure for performance fees and carried interest
- At least one illustrative example based on a £10,000 investment
Past Performance Disclosure
Past performance must be presented using:
- Up to 10 years of data (or lifetime if shorter)
- Net of costs, with income reinvested
- A line graph showing product and relevant benchmark
- Monthly data points
- Clear warnings and disclaimers
Additional requirements apply for:
- CEIFs and ETFs
- Feeder funds
- Non-GBP products (currency risk warnings)
How NeoXam Impress Helps
With NeoXam Impress, manufacturers and distributors can confidently address the new UK Consumer Composite Investment (CCI) disclosure requirements through a truly end-to-end reporting platform. Beyond ready-to-use regulatory templates, NeoXam Impress supports the full disclosure value chain, from raw accounting and ABOR data ingestion, through standardized calculations and analytics, to narrative editing, governance workflows, and controlled dissemination. This industrialized approach enables firms to produce Product Summaries and support disclosures consistently across regulatory frameworks, including UCITS, PRIIPs, and now CCI, while preserving flexibility in presentation and distribution. Backed by many years of experience supporting some of Europe’s most prominent fund administrators and asset managers, NeoXam combines regulatory expertise, scalable technology, and operational robustness to help institutions adapt smoothly to evolving disclosure regimes and consumer-focused regulation.
