The FCA published its final rules for Consumer Composite Investments on 8 December 2025, in PS25/20. Most of the commentary since has been written for manufacturers, because most of the 130 pages of made rules are about producing a product summary.
That has left a lot of advice firms with the impression that the regime is somebody else’s problem until a new document turns up.
It is not. PS25/20 defines a distributor in one sentence, and the sentence is wide: “A distributor of a CCI is a person who offers, advises on, or sells a CCI, or provides investment services relating to a CCI to retail investors.”
Advises on. If you recommend a fund, an investment trust, a structured product or a unit-linked policy to a retail client, you are a distributor of a consumer composite investment, and the regime gives you obligations of your own.
The dates, in the order they arrive
| Date | What happens |
|---|---|
| 8 December 2025 | FCA publishes final rules, PS25/20 |
| 6 April 2026 | CCI legislation commences, transitional period begins |
| 31 December 2026 | UCITS exemption from the PRIIPs Regulation expires |
| 7 June 2027 | Transitional period ends |
| 8 June 2027 | Full go-live, firms in scope must comply with the whole regime |
Eighteen months from publication to go-live, with fourteen of them as an optional transitional period. The FCA’s reasoning is that the rules “primarily alter existing obligations for firms rather than introduce completely new regulatory concepts”.
The one to put in the compliance diary now is 31 December 2026, and it is the one nobody is talking about.
Why 31 December 2026 is the adviser’s date
During the transition, manufacturers choose what they produce. From 6 April 2026 they may issue a CCI product summary; they may equally carry on with their existing document until go-live.
But the UCITS carve-out does not wait for go-live. The Handbook guidance is plain: a UCITS management company “is exempt from the PRIIPs Regulation until 31 December 2026” and should publish a key investor information document until that date. Managers of non-UCITS retail schemes offered to retail clients in the UK have the same choice “until 31 December 2026”.
So the practical effect is a staggered change in the documents that reach your file, starting ten weeks from now, running for eighteen months, during which:
- Some products will arrive with a UCITS KIID.
- Some will arrive with a PRIIPs KID.
- Some will arrive with a CCI product summary.
- The risk number on them will be on two different scales.
- The cost figure will be built on two different methodologies.
Your suitability file, your centralised investment proposition documentation and your client-facing comparisons all have to cope with that mixture without producing a comparison that is not a comparison. That is the real work of the next eighteen months, and it is not a project anybody is running yet.
What you actually have to do pre-sale
The FCA set a floor. Distributors must highlight, at a minimum:
- A brief explanation of the product.
- The ongoing costs figure of the product, and other costs relevant to the product, for example one-off costs.
- The risk and return score of the product and a brief explanation of the product’s risk and return profile, including any required warnings.
Three items. Note what the rule does not say: it does not require you to walk a client through the whole product summary. The FCA clarified during consultation that “pre-sale, distributors only need to highlight the information consumers need to make a properly informed decision, not all the information in the product summary”.
That is a deliberate loosening and it is genuinely useful. It means a well-built client journey can lead with the three things that matter and link to the full document, rather than burying a recommendation under a disclosure pack. The FCA says that beyond the minimum, “firms should use their own judgement under the Duty”.
Which is also the catch. A minimum plus judgement is a harder standard to evidence than a checklist, and it is the same structure as the consumer understanding outcome we looked at in suitability reports under Consumer Duty.
What you are not allowed to do
The consultation asked whether distributors should be able to produce or edit a product summary. Most respondents said no, citing liability for communications, and the FCA agreed.
The final rules are therefore restrictive on this point: distributors cannot make their own product summaries or change manufacturers’ product summaries. The document must be made available before a sale and provided to the consumer in a durable medium after any sale.
Firms that currently produce their own fund factsheets or in-house summaries that sit alongside a KID should check what those documents are doing. Supplementary material built from the manufacturer’s underlying data is encouraged. A document that reads as a substitute product summary is not.
Two numbers that will change what clients ask you
The risk indicator moves from 1 to 7 to 1 to 10
The PRIIPs summary risk indicator was a seven point scale. The CCI risk and return score runs “on a scale of 1 to 10”, and the renaming is substantive rather than cosmetic: respondents asked that the measure represent potential returns as well as risk, and the FCA agreed that firms should present “a balanced message on risk and return”.
Two consequences for an adviser.
First, a product that was a 4 out of 7 is not a 4 out of 10, and clients will read it as a reduction in risk. Anyone holding a portfolio through the transition will see both scales, possibly in the same review pack.
Second, illiquidity now moves the number. The original proposal made high illiquidity an automatic 9; after feedback the FCA amended it so that illiquidity “should increase the risk and return score by at least one to reflect the higher risk to consumers of not being able to access their money immediately”. Structured products move to a value-at-risk equivalent volatility model, which is a better fit for their profile and another reason the old and new numbers will not map onto each other.
The OCF becomes the headline, and transaction costs move out of it
The FCA consulted on a single aggregated summary cost. Respondents objected that bundling one-off costs into a figure representing twelve months would mislead, and that including implicit transaction costs produced numbers that were not meaningful.
The final position: the ongoing costs figure must be presented as the headline figure. Explicit transaction costs and one-off costs “do not need to be aggregated with ongoing costs, but they will need to be disclosed”. The requirement to disclose implicit transaction costs is removed.
For advice firms this is simplification with a sharp edge. The headline comparison number gets cleaner and more comparable between products. It also gets smaller, while the client’s actual total cost of ownership does not. Any firm that has built its charges conversation around a single aggregated figure will find the published number has moved and the real cost has not, which is precisely the gap we went through in total cost of ownership in discretionary wealth management.
What to do in the next quarter
Nothing in the regime requires a distributor to change anything before 8 June 2027. That is the trap, because the documents start changing on 31 December 2026.
A proportionate programme looks like this.
Before the end of this year. Ask each of your principal manufacturers and platforms one question in writing: when do you intend to switch from a KID or KIID to a CCI product summary? The answers will not be uniform, and the spread of answers is your implementation timetable.
First quarter of 2027. Decide how your pre-sale journey delivers the three minimum highlights, and write down that decision with its reasoning. That record is what an assessment under the Duty will ask for.
Through 2027. Review any in-house product documentation against the prohibition on distributor-made summaries, and update your risk mapping so a 1 to 10 score and a 1 to 7 score are never presented to a client as the same measurement.
Before go-live. Check that your CIP governance paperwork, model portfolio comparisons and attitude to risk mapping all reference the new scale. A committee pack comparing a legacy 5 with a new 5 is the sort of error that is invisible until somebody complains. Our note on building a centralised investment proposition covers where that documentation normally lives.
The honest summary
This is a disclosure reform, not a business model reform. It will not change who you advise or what you recommend.
What it will do is make the two numbers clients anchor on, cost and risk, incomparable across products for about eighteen months, while your obligation to equip them to make a properly informed decision stays exactly where it is. The firms that have trouble will be the ones that discover the mismatch in a review meeting rather than in a project plan.
Around 19 million UK adults hold retail investment products, on the FCA’s own Financial Lives figures. The regime exists because the documents describing those products were not doing their job. That is a reasonable thing to be doing, and it still lands as work on the desks of people who did not write the old documents either.
PS25/20 is published in full on the FCA’s website, and the rules themselves sit in the new DISC sourcebook in the Handbook.
Frequently Asked Questions
Does the CCI regime apply to advisers or only to product manufacturers?
Both. PS25/20 defines a distributor of a CCI as a person who offers, advises on, or sells a CCI, or provides investment services relating to a CCI to retail investors. An advice firm recommending a fund, an investment trust, a structured product or a unit-linked policy is a distributor of it, with its own obligations under the regime.
When does the CCI regime actually bite?
The legislation commenced on 6 April 2026 and the full regime goes live on 8 June 2027. In between is a transitional period that ends on 7 June 2027, during which manufacturers may produce either a CCI product summary or their existing PRIIPs KID or UCITS KIID. The FCA is explicit that distributor obligations remain as just to provide the relevant disclosure document until 8 June 2027.
What must a distributor highlight before a sale?
Three things, as a minimum: a brief explanation of the product; the ongoing costs figure and other costs relevant to the product, such as one-off costs; and the risk and return score with a brief explanation of the product's risk and return profile, including any required warnings. Beyond that minimum the FCA expects firms to use their own judgement under the Consumer Duty.
Can an adviser produce or amend a product summary?
No. The FCA adjusted its proposals in response to consultation feedback so that distributors cannot make their own product summaries or change a manufacturer's. The document must be made available before a sale and provided to the consumer in a durable medium after any sale.
What is changing about the risk indicator?
The PRIIPs summary risk indicator ran 1 to 7. The CCI risk and return score runs on a scale of 1 to 10, and it is framed as a risk and return score rather than a risk score alone, because the FCA wants a balanced message. Illiquidity must increase the score by at least one, and structured products must use a value-at-risk equivalent volatility model.
What happens to the ongoing charges figure?
The OCF becomes the headline cost figure. Explicit transaction costs and one-off costs still have to be disclosed but do not have to be aggregated into that headline number, and the requirement to disclose implicit transaction costs is removed. So the single comparable number clients see will be the OCF, and the costs above it will sit alongside rather than inside it.
Why does 31 December 2026 matter?
A UCITS management company is exempt from the PRIIPs Regulation until 31 December 2026 and publishes a UCITS KIID until then. Authorised fund managers of non-UCITS retail schemes offered to retail clients have the same choice until that date. After it the exemption is gone, which means the documents arriving on advisers' desks in early 2027 will change while the CCI go-live is still eighteen months off.