Four Key Challenges of UK CCI facing manufacturers and distributors

With the transition window starting in April 2026, asset managers need to start planning now

The FCA’s final UK Consumer Composite Investments (CCI) rules in Policy Statement 25/20 formally start the countdown for firms to migrate from PRIIPs and UCITS disclosures to the new CCI product summary, with an optional transition window from 6 April 2026 and full application of the regime from 8 June 2027 for all in‑scope manufacturers and distributors. As the market move towards implementation, four key challenges are already emerging for product manufacturers and distributors: interpreting which products are in scope of UK CCI, building end‑to‑end processes and data flows to produce compliant product summaries, adapting distributor systems and consumer journeys to integrate the new disclosures, managing parallel regimes and transition risk during the optional 18‑month period.

In parallel with these regulatory developments, FE fundinfo is preparing to support the industry by collecting your new CCI disclosure documents and disseminating them efficiently across our established network of platforms, and distribution partners, so that once your templates are finalised they can reach the wider market in a timely and controlled way.

Consumer Duty

The FCA requires manufacturers to complete their Product Summaries in line with the Consumer Duty requirements. In particular, the FCA has stated that manufacturers should complete consumer testing and retain evidence of this, and that layout and use of language must be clear, free of jargon and presented in a way that key information can be found easily.

MiFID costs and charges

The MiFID costs and charges rules in the UK were not amended in time for the publication of the final CCI rules. FCA has committed to addressing this in 2026 but, in the short term at least, the two disclosures will be different with manufacturers having to produce both sets of data and distributors receiving competing information.

Demise of UK UCITS KIIDs

The UK UCITS KIID extension is due to end by the end of 2026, meaning that UCITS manufacturers will have to switch to UK CCIs for their year-end update. This would mean that UCITS will have to adopt the CCI rules six months before all other products, unless a Statutory Instrument amending the law is enacted to allow for KIIDs to be extended to the June 2027 deadline.

Machine-readable digital format

The CCI rules have a lack of guidance around what core information should be made available to distributors and what form that information should take, other than it should be machine readable. In the absence of a FinDatEx equivalent in the UK, which produces the European MiFID (EMT) and European PRIIPs Template (EPT), FE fundinfo understands that several UK trade associations are working together and discussing what this template format should look like in order to be compliant with the CCI regulations.

The UK CCI regime becomes mandatory on 8 June 2027, with an optional transition period beginning on 6 April 2026. While this may appear to provide ample time, leading firms are already looking ahead. Rather than waiting for the compliance deadline, preparation should begin now.

At FE fundinfo, we provide an intelligent regulatory infrastructure, built to meet the demands of the UK CCI framework and help you navigate regulatory complexity with ease.

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UK Consumer Composite Investments (CCI) Regulations Mockup (3)

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Navigate UK CCI Requirements

Final FCA rules mark the beginning of the end for existing UCITS and PRIIPs consumer disclosures in the UK

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