Client update: FCA CCI regime – 4 key updates

As of earlier this month, PRIIPs has officially been removed from UK legislation (!) – we set out below 4 key updates for firms to have in mind now we are transitioning to the CCI regime.

1. Transitional period now in effect: action required

The optional transitional period for the FCA’s Consumer Composite Investments (CCI) regime has now commenced, following the entry into force of the relevant legislation on 6 April 2026. This marks a significant milestone in the UK’s move away from the PRIIPs and UCITS disclosure regimes to the new, outcomes-focused CCI framework. Firms now have the option to begin using the new CCI Product Summary in place of existing PRIIPs KIDs or UCITS KIIDs. However, all firms in scope must be fully compliant with the new regime by 8 June 2027, when the transitional period ends and the CCI rules become mandatory.

Many distributors are not yet ready to deploy the CCI Product Summary and are still requiring PRIIPs KIDs or UCITS KIIDs to be provided to them. We are aware of industry discussion amongst distributors as to whether it may be possible for industry to agree a date by which distributors will require the CCI Product Summary, ahead of the end of the transitional period. This could be as early as mid-February 2027 so that firms would avoid the need to run a UCITS KIIDs update in parallel with the creation of the new CCI Product Summary. While this would be a welcome relief for those firms who would be required to undertake a UCITS KIID update in February next year, it would mean an accelerated timetable to have Product Summary ready. We recommend that firms follow industry discussions carefully to ensure they are ready to deploy bearing in mind the need for robust internal review, consumer testing, and system updates.

2. No standard industry template – FCA’s position on innovation

To date, no industry body or document creation provider has published a standard template for the CCI Product Summary. This is consistent with the FCA’s policy intention: the regulator has deliberately avoided mandating a template, instead encouraging firms to innovate and design disclosures that genuinely support consumer understanding and good outcomes. The regime is expressly underpinned by the Consumer Duty, meaning that disclosure effectiveness - not just technical compliance - will be measured. Firms subject to the Duty must be able to evidence that their disclosures support good consumer outcomes, which is likely to require firms to determine whether they will need to undertake consumer testing.

Whilst approaches to product design are likely to be discussed at industry level, we are of the view that firms will need to push ahead with their own design of their Product Summary format and satisfy themselves that this meets the FCA’s requirements and supports good consumer outcomes. We would recommend taking a look at the IA’s Risk Warnings Review and the practical guidance that it published on 9 April 2026 and consider its application to CCI Product Summary drafting.

In relation to the core information disclosures, FinDatEx announced that it will start work to update UK-specific fields in the European MiFID Template (EMT) and the European PRIIPs Template (EPT) to reflect the requirements of the FCA's CCI regime. The respective working groups will commence work soon with the aim of publishing revised EMT and EPT in early 2027.

3. FCA consultation on MiFID costs and charges

Industry will be aware that, with the introduction of CCIs, a divergence will be created between the cost and charges disclosures required under the CCI regime and the cost and charges disclosures required under the MiFID regime (which draws on the PRIIPs methodologies). The FCA have acknowledged these discrepancies and are holding an industry roundtable on MiFID costs and charges disclosures this week and will look to consult on these changes as soon as possible, which we understand will be at some point this summer.

4. Will a CCI Product Summary be a financial promotion?

It is important to note that the CCI 2024 SI removes the exemption for PRIIPs KIDs from the financial promotion restriction for CCI Product Summaries. The FCA have confirmed verbally that this was an intentional change, as the CCI Product Summary is a free form document, the exemption is no longer appropriate in the FCA’s view because firms have more discretion around how they display information in the Product Summary than they did with the PRIIPs KID. This means that firms will need to approve Product Summaries as retail financial promotions or find someone with the approver permission to do so.

We are exploring the implications of this with some of our manufacturer clients.

For further advice on implementation or to discuss your firm’s approach to the CCI regime, please contact one of the contacts listed below or your usual Simmons & Simmons contact.