Author:

Lewis Davison
Vice President of Product at Confluence

Almost a year since the initial consultation paper (CP24/30), and several months after the subsequent consultation paper (CP25/9), the FCA’s final Consumer Composite Investments (CCI) rules arrived via Policy Statement (PS25/20) on 8 December 2025.

This starts the timer on a crucial shift in UK retail investment disclosures.

There are many positive developments here that both simplify and clarify expectations on in-scope firms – manufacturers and distributors of CCIs which includes open and closed-ended funds, insurance products, and other retail investment products such as structured products and derivatives.

The FCA has more work planned to revisit and reshape related frameworks including the Consumer Duty and onshored MiFID rules, planned for 2026. But, for now, this is a positive step forward and will be welcomed by many.

Turnout was high on the consultation responses, with a significant response from the closed-ended sector – 115 respondents out of 211 (~55%) for CP24/30, and 77 out of 109 (~70%) for CP25/9. The Cost Disclosure Campaign achieved 467 signatories to its CP24/30 response. Clearly, this matters – we ourselves joined the industry response here in support of a more effective and proportionate framework.

Below, we break down the key takeaways you need to know.

For Confluence, this marks the next step in our journey to adapt our existing PRIIPs and UCITS disclosure solutions, building on the comprehensive design initiative we presented in our recent client workshops. As ever, if you would like to raise any questions and talk to us about how we can help you navigate the incoming CCI framework, please get in touch.

Key Headlines:

• Timeline - An 18-month transition period will apply for all in-scope firms, removing the previously proposed 12-month transition period for closed-ended funds. The transition period ends 7 June 2027, with firms able to migrate to the new framework from 6 April 2026 when the legislation commences.
• Scope - Broadly unchanged but simplifies the de-scoping of retail products – the minimum investment amount of £50k is removed, retaining existing marketing restrictions and oversight requirements.
• Manufacturer & Distributor roles - to address practical and liability concerns, distributors will now not be able to modify the product summary – being the sole responsibility of manufacturers. The minimum information a distributor needs to provide is clarified.

• The Product Summary
• Retains flexibility in the product summary design and layout, with prescription in certain areas as previously proposed.
• Core information required remains unchanged.
• Greater flexibility in narrative descriptions allowed, to ‘downplay’ information where contextually appropriate.
• Machine-readable file still required for manufacturers to share information with distributors.
• Retains existing proposed flexibility for the presentation of product summary information by insurance firms, including those running multi-option products (MOPs).
• Costs
• The FCA has, sensibly, removed the need to aggregate one-off and ongoing costs into a single figure, which was never practicably workable. Instead, the FCA requires only the ongoing charges figure (OCF) as the headline cost figure.
• We already directionally knew implicit transaction costs (TCs) were being removed via CP25/9, however the FCA have confirmed that explicit TCs do not need to be presented alongside OCF in e.g. a breakdown of costs table. Rather, explicit TCs can be incorporated into e.g. the product strategy description to encourage contextualisation. In a subtle nuance, it appears that explicit TCs only need to be presented in £ and pence, unlike the OCF (which must also be presented as a % value). This better reflects their nature i.e. they are not set by the fund and are more variable.
• The perceived passive ‘bias’ has been removed – look-through will be required for both passive and active strategies to produce a synthetic OCF where investing in other CCIs (excluding closed-ended funds, see below).
• For closed-ended funds, while direct ‘ongoing costs’ must still be presented, where other CCIs invest in closed-ended funds they do not need to incorporate the underlying costs into a synthetic OCF, albeit the costs of underlying closed-ended funds must be made transparent and presented to investors. Similar transparency applies to performance fees.
• The removal of look-through costs (into the OCF) here has been widely welcomed by the closed-ended sector to avoid the ‘double-counting’ issue so heavily contested. For direct ongoing costs, there is significant flexibility to explain and contextualise the nature of these costs and how they operate in practice.
• No CCIs will need to include gearing or real asset maintenance costs in their OCF – extending the exemption from closed-ended funds only.
• Where costs are not applicable (e.g., if entry/exit costs are 0), then the illustration / breakdown of costs need not show a row with zero values, simplifying the information delivery.
• UK MiFID will be more widely reviewed in 2026 including costs and charges disclosures. For now, the cumulative effect of costs continues to be a requirement for presentation to investors under this framework.
• Better calibrates the presentation of performance fees, with illustrative (hypothetical) example(s).

• Risk & Return
• Amends the description of the risk score to clarify that it is a risk and return score, to better balance the two aspects.
• Moves to a 10-year price history for the volatility-based risk indicator calculation, up from 5 as initially proposed. Firms must simulate historical pricing using an appropriate proxy or benchmark where less than 10 years’ history is available, wherever possible.
• Illiquid products no longer default to a ‘9/10’ on the risk indicator. However, they must increase their calculated score by +1 if they invest in illiquid assets and/or have mechanisms to delay, or penalties for, early divestment. More objective assessment will be required for derivative-based and leverage products.
• Structured products will now be subject to a VaR-equivalent Volatility (VEV) based risk measure, to better reflect the nature of these products.
• There appears to be no routine ongoing monitoring requirement for the risk indicator – the FCA confirms that products need only produce the product summary annually unless there is a material change. Products which might fluctuate between two risk categories across any annual period are not deemed to require re-publication of their product summary outside of the annual requirement.
• Distributors may provide additional contextual information e.g. comparisons on reduction in purchasing power vs. holding cash alone.

• Past Performance
• Confirms the X-axis does not need to reflect calendar years, where not appropriate to the product.
• The PS ups the minimum required data points for past performance to monthly, from quarterly.
• Removes the need to show pre-merger information – only retaining post-merger performance.
• Where a material change to the fund’s objectives and strategy have occurred, the period prior to this change should be compared to a prior, appropriate benchmark, and not necessarily the current one.

• Additional Information – No real change here other than a confirmation that complaints-related information can be cross-referenced (i.e. linked) in the PS, rather than set out in more descriptive terms.

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