UK CCI and EU PRIIPs: Key Regulatory Differences

A Side-by-Side Analysis of Costs, Risk, and Performance Requirements

With the FCA finalized the UK Consumer Composite Investments (CCI) framework, marking a definitive break from the EU's PRIIPs regime. For asset managers distributing to UK retail investors, this isn't just a regulatory update. It's a strategic inflection point. There is no prescribed template or page limit applicable to the product summary document.

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, we believe preparation should begin now. Early planning and collaboration will allow firms not only to manage implementation smoothly, but to approach the transition strategically — positioning themselves ahead of the curve and fully prepared well before the regulatory clock runs out.

Let's break down what's changed—and what it means for your operations.

Costs and Charges: Simpler, Clearer, More Transparent

The FCA has streamlined cost disclosure requirements in ways that should make compliance easier and investor communication clearer.

What's Changed:

Implicit transaction costs removed – only explicit costs need to be disclosed

OCF restructured – one-off charges (entry/exit fees) now disclosed separately, not bundled into ongoing costs

Dual disclosure format – all costs shown as both percentages and GBP amounts based on a £10,000 investment

Real estate and leverage adjustments – gearing costs and real asset maintenance expenses excluded from OCF

Structured product clarity – lifetime costs disclosed upfront when known in advance

The Challenge: Firms will need to reconfigure cost calculation engines and reporting systems to separate one-off from ongoing charges—while maintaining parallel PRIIPs calculations for EU distribution. For firms with hundreds of share classes, this dual-track reporting requirement creates significant operational overhead and heightened risk of errors.

Risk and Return: More Granular, More Context

The FCA has taken a more sophisticated approach to risk disclosure—one that better reflects long-term investment realities.

What's Changed:

Expanded risk scale – from 1-7 to 1-10, providing finer gradations

Longer assessment period – risk calculated over 10 years instead of 5 (with simulated data permitted for newer products)

Renamed section – now "Risk and Return" to emphasize the relationship between the two

Structured products methodology – shift to Value-at-Risk Equivalent Volatility (VEV) method

Pre-set ratings – certain high-risk products (e.g., CFDs, contingent convertibles) automatically assigned minimum risk scores

The challenge: In a change to EU PRIIPs KIDs, UK CCI has moved the risk and return scale from 1 – 7 to 1 – 10 means rebuilding risk models and data infrastructure. The score must be calculated using daily prices over ten years or use simulated performance or an appropriate benchmark where ten years information is not available.

Past Performance:

After years of PRIIPs' controversial performance scenarios, the FCA has brought back something investors actually understand: historical performance charts.

What's Changed:

10-year line graph reinstated – plotting actual performance alongside an appropriate benchmark

Standardized investment base – performance shown based on £10,000 (or currency equivalent divisible by 1,000)

Monthly data points – more granular than PRIIPs' approach

Positioning requirement – performance must appear lower in the Product Summary (to prevent undue emphasis)

The Challenge: Sourcing and validating 10 years of monthly performance data—especially for merged funds, rebranded products, or those with complex benchmark histories—creates substantial data governance burdens. Firms will need to maintain different performance presentation formats to meet divergent UK and EU reporting requirements, multiplying the compliance workload.

Ready to prepare for UK CCI? Download the full briefing guide

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

Client Briefing Guide

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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