UK Retail Product Disclosure Regime for Consumer Composite Investments: From UCITS KIIDs and PRIIPs KIDs to CCI Product Summaries

September 2026

The United Kingdom has introduced a new disclosure regime for investment products that are made available to retail investors in the United Kingdom. The new requirements apply to consumer composite investments (CCIs) and took effect on 6 April 2026. The CCI regime is a significant regulatory change that applies to any firm—including non-UK firms—that make investment products that are CCIs available to retail investors in the United Kingdom. 

Key Impact for Firms

As part of the new regime, product manufacturers have until 7 June 2027 to replace their current retail product disclosure—whether a UCITS KIID or PRIIPs KID—with a new CCI product summary (Product Summary). There are also changes to the information that product manufacturers must make available to distributors and other intermediaries that make investment products available to retail investors in the United Kingdom. Manufacturers and distributors of CCIs should start preparing for the new disclosure requirements, including the following:

• Identifying all products that will fall within the scope of the CCI regime.
• Developing template Product Summaries that conform to the CCI requirements.
• Ensuring they have the necessary data and processes to calculate and present performance and risk indicators in accordance with the CCI requirements.

Preparing and generating new Product Summaries may be a significant and time-consuming task, depending on the number of products involved.

The Regulatory Framework for CCIs

The United Kingdom created a new framework for the regulation of CCIs as part of a broader review of the regime for consumer investments in the United Kingdom and a post-Brexit review of retained EU law and regulation. That framework was established by the Consumer Composite Investments (Designated Activities) Regulations 2024 (CCI Regulations), which gave new powers to the Financial Conduct Authority (FCA) to make rules relating to CCIs. A crucial point to know is that the CCI Regulations extend the FCA’s regulatory perimeter to include firms carrying on certain “designated activities” involving CCIs even if those firms are not FCA authorised and are based outside the United Kingdom.

What Is Changing?

The CCI disclosure regime has the following two key components:

Product Summary

A requirement for manufacturers of CCIs to produce a summary meeting certain content requirements, including information on costs, a risk and return indicator, and past performance. This replaces the key information document required under the Packaged Retail and Insurance-based Investment Products regime (PRIIPs KID) and the key investor information document required for Undertakings for Collective Investment in Transferable Securities (UCITS KIID).

Core Information Disclosure

A requirement for manufacturers to make certain core information about CCIs available to distributors in a machine-readable format. Distributors are required to provide the Product Summary and key information (if not otherwise included in the Product Summary) about the product to retail investors. 

The detailed requirements are set out in new rules in the FCA’s Product Disclosure Sourcebook (DISC). 

Scope of the CCI Regime

What Is a CCI?

A CCI refers to “an investment where the returns are dependent on the performance of, or changes in, the value of underlying or reference assets.” It includes the following:

• Investment funds, including recognised funds (such as European Economic Area UCITS recognised under the United Kingdom’s Overseas Funds Regime).
• Structured products and structured deposits.
• Contracts for difference.
• Insurance-based investment products.
• Other complex products, such as derivatives.

Certain products are expressly excluded from the CCI definition, such as plain vanilla listed bonds, equity shares in commercial companies, pure protection life insurance, deposits (other than structured deposits) and pension schemes. CCIs that are “non retail” are exempted from the obligations in DISC provided the manufacturer has taken certain reasonable steps, including that the offer and any associated communications are directed only to nonretail investors.

Who Does the CCI Regime Apply To? 

The CCI regime applies to manufacturers and distributors of CCIs. There are four “designated activities” prescribed in the CCI Regulations that set the scope of firms subject to the CCI regime, which are the following:

• Manufacturing a CCI made available to a retail investor in the United Kingdom.
• Advising on a CCI for a UK retail investor or their agent.
• Offering a CCI to a UK retail investor.
• Selling a CCI to a UK retail investor.

“Retail investor” for these purposes refers to a person who is or would be categorised as a retail client under the FCA rules or would meet that criteria if a regulated activity was involved.

Does It Apply to Firms Outside the United Kingdom and to Non-FCA-Authorised Firms? 

Yes. The new regime is not limited to UK firms or FCA-authorised firms. This means that firms based outside the United Kingdom and firms that are not regulated by the FCA may still be subject to the CCI regime if they manufacture or distribute investment products that are made available to UK retail investors. By way of example, the CCI regime will apply to the following: 

• An overseas manufacturer of a CCI (such as an EU UCITS management company of a UCITS distributed to a retail investor in the United Kingdom). 
• An overseas distributor of a CCI that distributes a CCI in the United Kingdom even if it is not required to be FCA authorised (e.g. because it is able to rely on the overseas persons exemption).

Such firms will be within the FCA’s regulatory perimeter, and they will need to comply with the relevant FCA rules in DISC.

What Are the Disclosure Requirements?

Information to Be Provided to Distributors

The manufacturer of a CCI must provide the following to the distributor before the CCI is made available for distribution to retail investors:

• The Product Summary.
• The Core Information Disclosure.
• Additional information on target market, assessment of value, risks for retail investors and distribution strategy (some of which will overlap with the Core Information Disclosure).

The information and materials can be provided by posting on a website. Manufacturers must revise and update the Product Summary and Core Information Disclosure as necessary to ensure they remain up to date, and they must review the Core Information Disclosure at least once in every 12-month period.

Information to Be Provided to Retail Investors

A CCI may only be distributed to a retail investor in the United Kingdom—whether directly by the manufacturer or by a distributor—if an up to date Product Summary is made available to the retail investor at an appropriate stage and in a durable medium. In addition, firms must “take reasonable steps to promote engagement by the retail investor” with information on characteristics of the product, fees, risk and reward score, relevant material risks and risk warnings. 

The Core Information Disclosure and other information required to be provided to distributors are not required to be passed on to retail investors. However, distributors are expected to use such information, for example, to prepare communications that are more likely to be understood or engaged with by the relevant retail investors. 

Where a retail investor asks to invest in a CCI at their own initiative without the firm promoting the CCI or advising the retail investor on the merits of investment in the CCI (sometimes termed a “reverse solicitation”), then it is sufficient to only provide a copy of the Product Summary in durable medium at the point of sale. In such circumstances, the firm must take reasonable steps to encourage the retail investor to consider the Product Summary before they invest or become bound by an agreement to invest.

Product Summary—What Information Must Be Included?

The Product Summary is the retail-facing disclosure, and it must convey “as a minimum the Core Information Disclosures.” The purpose is to set out appropriate information about the essential characteristics of the CCI.

Unlike the current UCITS KIID or PRIIPs KID, the format of the Product Summary is not prescribed, and there is no template. There remains a degree of standardisation for some elements, which is intended to facilitate comparisons between CCI. 

The following information must be included in a Product Summary:

General Product Information

This includes the fund name, international securities identification number (ISIN) or other identifier, manufacturer, objective and strategy, recommended holding period, and complaints/redress procedures.

Costs and Charges

This requires disclosure of ongoing cost, entry costs, exit costs, transaction costs, and performance fees or carried interest. Costs must be disclosed showing the gross costs in relation to an assumed investment of £10,000. 

Risk and Return

A risk-and-return score calculated using the prescribed methodology and presented in the prescribed format using a numbered scale from 1 (lower risk) to 10 (higher risk). The calculation methodology is based on the standard deviation of returns over a 10-year period, with the exception of structured products where a value-at-risk (VaR) method should be used.

Past Performance

Performance for the last 10 years must be presented in a line graph. Performance must be net of any costs and charges, and it must show cumulative performance calculated at monthly intervals (rather than quarterly). For UCITS and non-UCITS retail schemes that have a target benchmark or constraining benchmark, the line graph must include the performance of the benchmark. This is optional for comparator benchmarks.  

The content requirements for the Product Summary have some similarities with the previous UK UCITS KIID and UK PRIIPs KID. The table appended to this alert compares the content requirements for the Product Summary with the UK UCITS KIID and UK PRIIPs KID requirements. 

Separately, in relation to the costs disclosure, the FCA is aware of the discrepancy between what will be disclosed under the CCI regime and what a firm is required to disclose under the Markets in Financial Instruments Directive (MiFID) derived requirements. The FCA has proposed changes to align the MiFID cost disclosures with the CCI requirements in Consultation Paper CP26/24, and the final rules are expected to be published by the end of 2026.

Core Information Disclosure - What Must Be Included?

The Core Information Disclosure refers to the essential information regarding a CCI, and it underpins the Product Summary. It covers the categories described above: (i) general product information, (ii) costs and charges, (iii) risk and return, and (iv) past performance.

The Core Information Disclosure must be made machine readable when provided to distributors. The machine readability requirement will not apply if the manufacturer will itself distribute the CCI product or uses its associates to distribute the CCI product. 

It is expected that this can be addressed through industry disclosure standards. FinDatEx has announced it has commenced a targeted review of the European MiFID Template (EMT) and European PRIIPs Template (EPT) focusing on the CCI-specific changes, and it has stated its aim of publishing a revised EMT and EPT in early 2027.

What Should Firms Be Doing?

Agree on Project Timing

The new FCA rules in DISC took effect on 6 April 2026. There is a transitional period until 7 June 2027. During this transitional period, firms may choose to produce a CCI Product Summary or continue to produce a UCITS KIID or PRIIPs KID (as appropriate) for the relevant product. Most firms are expected to switch to Product Summaries at the time of the next annual update of their UCITS KIIDs in the first quarter of 2027.

Develop Product Summary Template

For firms that use third-party providers to generate UCITS KIID and PRIIPS KID disclosures, this will require interaction with the service provider to develop and agree the Product Summary template. Given the flexibility of the regime, variations in layout and approach are expected.

Prepare to Populate Product Summaries

Manufacturers should revisit the description of their products before populating Product Summaries. It should not be assumed that narrative descriptions of products can simply be ported from PRIIPs KIDs and UCITS KIIDs into Product Summaries. Manufacturers should consider whether descriptions should be subject to consumer testing (or equivalent) to ensure they are understandable to retail investors. They must also ensure they can prepare performance information and risk indicators using the prescribed calculations and meeting the prescribed format requirements.

Prepare to Populate Core Information Disclosures

Manufacturers should ensure they have the necessary data available (mostly required for Product Summaries) and monitor the development of revised EMT and EPT spreadsheets incorporating the CCI Core Information Disclosure requirements.

Click here to see our Table Summary of Key Differences between the PRIIPs KID, UCITS KIID and CCI Products.