Preparing for what’s next in UK Retail Disclosures

The final rules make a number of targeted changes vs. the initial consultations, which have generally been well received by the market and represent a more pragmatic, proportionate outcome.

This is, however, a significant regulatory transformation overall, and the direction of travel is clear: a greater emphasis on consumer understanding to empower investors to make timely and well-informed decisions.

This guide breaks down the FCA’s final CCI rules in practical terms from an asset manager’s perspective – what’s changing, who’s impacted, and what decisions firms need to make now. It also outlines how Confluence is responding to the framework to support firms at every stage, from disclosure design and consumer testing to data management, production and downstream activities.

If you’re an asset manager distributing to UK retail investors, this guide is for you

The Consumer Composite Investments (CCI) framework is the Financial Conduct Authority’s (FCA)
approach to replace PRIIPs and UCITS product disclosures in the UK.

The framework introduces changes to the format and content of existing disclosures, which under the
CCI will be referred to as a ‘Product Summary’. On format, and unlike the PRIIPs and UCITS frameworks,
the FCA is not proposing a fixed template layout and design, providing flexibility. However, on content,
the FCA is prescriptive on a baseline set of information to be included in the Product Summary,
particularly around costs, risk and past performance.

The CCI framework is supportive of a shift towards a digital-first, interactive approach to the disclosure
of such information. This theme is consistent with the direction of travel in the EU relating to product
disclosures, such as those under the PRIIPs framework (via the ‘PRIIPs modernisation’ proposal).

The framework also formalises a data exchange obligation, with manufacturers required to deliver core
product information to their distributors, something the market has been doing voluntarily for some time.

The CCI framework was first proposed in December 2024 (via consultation paper CP24/30), with a
subsequent follow-up consultation published in April 2025 (CP25/9).

The final Policy Statement makes numerous revisions vs. the initial consultation process. Key changes include:

1. Scope – clarification on the exclusion of ‘plain vanilla listed bonds’ and bonds tracking Interbank Offered Rates.
2. Timing – all products are given an 18-month transition period (to 8 June 2027), replacing the 12-month transition period initially proposed for investment companies. Firms can still transition earlier, with the CCI framework live from 6 April 2026.
3. Product summary – removes the ability for distributors to modify the manufacturer’s Product Summary; only a manufacturer will control the production of the Product Summary itself.
4. Risk & return
   • Extends the price history required for the risk indicator calculation from five to ten years.
   • Introduces greater flexibility for illiquid funds vs. automatic categorisation as 9/10 on the risk indicator scale.
   • Eliminates the need to present pre-merger information in the past performance chart where funds have merged – focusing only on the post-merger period.
5. Costs
   • Eliminates the initial proposal to combine one-off and ongoing costs – only the Ongoing Charges Figure (OCF) will be the headline figure.
   • Look-through costs apply to both passive and active funds (vs. passive-only as proposed initially).
   • Investments in closed-ended funds (e.g. investment companies) are not subject to look-through costs for the calculation/presentation of a synthetic OCF. However, the ongoing costs of such underlying vehicles should still be disclosed separately.
   • No need to disclose ‘zero’ cost categories e.g. entry/exit costs if they do not apply.
   • Explicit transaction costs can be explained in an investment policy/strategy section, with only a monetary figure (vs. £10,000 investment amount) needing to be disclosed.

The CCI framework will apply broadly to investment products marketed to retail investors in the UK. This will impact both domestic UK firms and non-UK firms who are marketing retail investment products in the UK under the FCA’s Overseas Funds Regime (OFR).

Rules will apply to:

• Manufacturers of retail investment products
• Distributors who offer, advise on, or sell those products to UK retail clients

Products impacted include:

• Open-ended funds (e.g. OEICs and Unit Trusts (UCITS or AIFMD))
• Closed-ended funds (e.g. investment companies and Venture Capital Trusts (VCTs))
• Structured products and deposits
• Derivatives and contracts for difference (CFDs)
• Insurance-based investment products (IBIPs)
• Securities which embed a derivative
• Debt securities with specific features
• Contingent convertible securities
• Any other investment where the returns are dependent on the performance or changes in the value of indirect investments

The FCA has also confirmed the product types considered out of scope:

• Pension schemes
• Non-structured deposits
• Protection-only insurance contracts
• Long-term insurance contracts (benefits payable only on death or sickness)
• Non-equity transferable securities issued by central banks or government/local authorities
• Qualified Investor Schemes (QIS) and Authorised Contractual Scheme (ACS) funds (confirmed in CP 25/9)
• Plain vanilla listed bonds and those tracking an Interbank Offered Rate

Firms may transition from producing existing KID/KIID disclosures to the new CCI Product Summary at any point between 6 April 2026 and the 8 June 2027 application date. Many firms plan to produce their first CCI Product Summaries by end-Feb 2027, transitioning earlier than the ultimate deadline in order to avoid the UCITS KIID annual refresh cycle.

Date	Timeline
8 December 2025	Policy statement published (final rules)
6 April 2026	Transition period began
8 June 2027	Application date (all firms)

Product manufacturers are tasked with two main deliverables:

1. A standalone product summary reflecting core product information
2. A machine-readable dataset containing the core product information relating to the product summary, to be delivered to distributors

As outlined above, the product summary does not have a fixed FCA-defined layout and design (unlike PRIIPs and UCITS KID/KIIDs), leaving a good level of flexibility for firms. However, this flexibility highlights the need for firms to engage in a consumer testing cycle, to ensure their final disclosure approach is fit for purpose in light of the UK Consumer Duty rules.

While the existing requirement to deliver disclosures in a ‘durable medium’ is retained (in practice, PDF), the FCA is actively encouraging a digital-first approach via online delivery of interactive and layered disclosures. This is equally a trend in regulatory approach that is emerging in the EU.

The product summary broadly covers:

• Core product information
• Product costs
• Risk and return information
• Past performance
• Additional practical information, including complaints and redress information

This should be updated at least annually as well as following any material change – however this is not defined in specific terms with respect to e.g. monitoring for risk indicator changes.

The FCA defines a range of information to be disclosed, including (but not limited to):

Alongside the product summary is a requirement to provide this core product information in a machine-readable format to distributors – in effect, a data-file version of the product summary. In practice, industry data-exchange frameworks (such as those created by FinDatEx) are already well established and widely utilised. Industry association discussions continue on this subject to determine a go-forward data exchange schema. Final versions of these industry data formats are not however expected until late 2026/early 2027.

The FCA’s final rules remove the notion of an ‘aggregated’ total cost, instead focusing on the Ongoing Charges Figure (OCF) as the headline cost figure to be disclosed.

Costs to be disclosed include:

• One-off entry and exit costs
• Ongoing costs,
  • including: Look-through to investments in underlying CCIs
  • excluding: Closed-ended Investment Funds (CEIFs), including investment companies, which should be presented as a separate ongoing cost relating to investments in these underlying vehicles, but should not be pulled through to the OCF itself.
• Explicit transaction costs
• Incidental costs (e.g. performance fees, carried interest) – performance fees arising from investments in underlying CCIs including CEIFs should also be made clear, including any potential conflicts of interest. An illustrative example should be included in disclosures to show how performance fees operate, where applicable.

Corresponding changes will be made in the assimilated MiFID Org Reg to simplify cost disclosures and ensure alignment with the CCI framework. However, this will follow later and is not immediately aligned to the CCI timeline. Further consultation and detail are expected in 2026.

The FCA has removed forward-looking performance scenarios (as under PRIIPs) in favour of a past performance presentation.

Past performance should cover up to 10 years of data (as available) and should reflect full calendar years where possible, or parts thereof if applicable. If less than 10 years of data is available, firms must present what is available; and if under 12 months, data points should be shown at an appropriate frequency accompanied with a clear explanation. Past performance presentation is not required for products with under three months’ history.

Performance must be displayed as a line graph, using at least monthly data points. The graph should show the growth over the historical period of a representative
£10,000 investment amount (or currency equivalent divisible by 1000 and of a similar magnitude) and include relevant benchmark comparisons aligned with the prospectus.

The FCA outlines three ‘types’ of past performance chart (for relevant CCIs).

1. A ‘standard’ line graph showing growth of £10,000 (and vs. benchmark(s))
2. Where a material change has occurred to the investment objectives and strategy, it should be clearly highlighted on the graph with appropriate commentary
3. For closed-ended investment companies, the graph should show a comparison of NAV and share prices

To note – the FCA initially proposed a fourth variant, such that merged funds should show pre- and post-merger performance. However, in a bid to simplify presentations, the FCA confirmed via its Policy statement that only the post-merger performance need be presented. For feeder funds, past performance should be specific to the feeder fund rather than the performance of the master fund.

The FCA’s proposals on risk and return disclosure have been broadly welcomed as a pragmatic step towards a clearer, more user-friendly presentation. Importantly, the focus shifts from emphasising risk warnings to more informative content that aids investment decision-making. To this end, products must include a concise risk and return description alongside the risk indicator and past performance.

A horizontal risk indicator is retained, with changes from the existing PRIIPs and UCITS approach:

• The risk indicator is based on a standard deviation approach, using a 10-year history (with benchmark/ proxy data required for backfill blending purposes).
• The risk indicator scale moves from a 1-7 scale to 1-10, for greater product differentiation.
• High-risk products default to at least a ‘9’ on the scale, with firms required to assess product characteristics accordingly. Scores may be revised up and down where appropriate and considering the product type and features.
• Where a standard deviation-based approach is unsuitable, firms must consider broader product features and risk factors to support a risk categorisation.

FCA conversion table highlighting how the proposed 1-10 scale relates to existing PRIIPs 1-7 score (for the market risk measure):

New score	Standard deviation range (%)	Corresponding old MRM score
1	< 0.5	1
2	0.5 – 2.0	2
3	2.0 – 5.0	2
4	5.0 – 9.0	3
5	9.0 – 12.0	3
6	12.0 – 16.0	4
7	16.0 – 20.0	4
8	20.0 – 30.0	5
9	30.0 – 50.0	6
10	> 50.0	6-7

Some of the key impacts and challenges we anticipate include:

Supporting impacted firms in the UK and beyond with the CCI transformation is a key commitment for us.

We are actively progressing our end-to-end CCI solution to support all production aspects, from data transformation and calculation through to document production, downstream dissemination and data exchange.

Following our focused design phase for our baseline Product Summary, Confluence is leading here in undertaking consumer testing phases to support clients in their Consumer Duty obligations.

With most firms planning to adopt CCI by early 2027 (to avoid the annual UCITS KIID refresh), Confluence is positioned to support these early adopters with implementation, testing and rollout completion in 2026.