The FCA concluded that the PRIIPs KID and UCITS KIID formats were not working for retail investors. In the FCA's own behavioural testing, participants described existing KIDs as "dense, technical, and highly templated" — documents that were not widely read, and among those who did read them, were not widely understood.

Specific criticisms of the PRIIPs regime included the mandatory scenario-based performance projections, which were widely found to be unrealistic and potentially misleading — producing figures that bore little relation to actual investment outcomes.

CCI is the FCA's answer: a principles-based framework that replaces rigid templates with design freedom. The core shift is from procedural compliance (follow the prescribed format) to interpretative compliance (exercise judgement to ensure disclosures genuinely help investors). This places more accountability on investment managers — and more opportunity to differentiate.

CCI is explicitly anchored in the FCA's Consumer Duty framework, which requires firms to deliver good outcomes for retail customers across four areas: products and services, price and value, consumer understanding, and consumer support.

Under Consumer Duty's Monitoring outcome, firms need evidence that their disclosures are genuinely working — not just that they've been produced and made available. This means investment managers should track engagement signals such as:

• Time spent on specific sections of the Product Summary or fund page
• Scroll depth on the risk disclosure content
• Document download rates for the Product Summary PDF

If investors are spending fewer than 30 seconds on risk disclosures before making a purchase decision, this may be evidence that the disclosure is not being effectively consumed — a potential regulatory issue under Consumer Duty.

The CCI regime applies to any firm that manufactures or distributes a Consumer Composite Investment to retail investors in the UK. In-scope products include:

• OEICs and unit trusts
• UCITS and non-UCITS retail schemes
• Exchange-traded funds (ETFs)
• Closed-ended investment funds
• Structured notes and products
• Structured deposits
• Insurance-based investment products (IBIPs)
• Recognised overseas funds (OFR / TMPR)

Products distributed solely to professional investors under the National Private Placement Regime (NPPR) are excluded from the CCI scope.

Yes. The FCA has confirmed that the CCI regime applies to both FCA-authorised firms and overseas entities that manufacture or distribute CCIs to retail investors in the UK. FCA authorisation is not a prerequisite for scope.

US, Asian, and other non-EEA managers whose funds are registered under the Overseas Funds Regime (OFR) or Temporary Marketing Permissions Regime (TMPR) are equally in scope as manufacturers. If your firm promotes products to UK retail consumers, the CCI obligations apply to you.

Distributors — including platforms, wealth managers, IFAs, and execution-only brokers — have distinct but related CCI obligations separate from manufacturers:

The FCA has not prescribed a fixed layout, but has mandated specific content under PS25/20. The Product Summary must meet four overarching requirements — technology neutral, outcomes focused, standardised only where needed, and right information at the right time. The following content elements are mandatory:

No. One of the FCA's four core Product Summary requirements is that it must be technology neutral — meaning the format must work digitally and in print, without prescribing any specific delivery medium.

The FCA explicitly supports digital-first, layered disclosure approaches. This means manufacturers can deliver the Product Summary as a web page, an interactive digital document, a PDF, or a combination — provided the disclosure is fair, clear, and not misleading, and that the most critical information is presented first.

However, manufacturers must also ensure a durable medium version of the Product Summary — typically a PDF — is available for download and provided to investors at the point of sale where required.

The machine-readable Core Information file — typically a CSV or XML — is a mandatory CCI requirement, not an optional supplement. Distributors use it to ingest your standardised cost and risk data into their own platforms and sales journeys. They don't display your PDF — they render your structured data in their own interface.

When evaluating CCI vendors, ask whether they produce only a Product Summary or also the Core Information file. These are different outputs requiring different capabilities. Kurtosys produces both from the same data pipeline, updated automatically whenever underlying data changes.

The CCI Product Summary must be reviewed and updated at least annually. In addition, it must be updated promptly whenever there is a material change to the product that would affect the information in the summary — including changes to costs, the Risk and Return Score, investment policy, or target market.

The publicly hosted version (on the fund website or digital platform) must always reflect the current, accurate data. Hosting an out-of-date Product Summary when material information has changed is a compliance risk under both the CCI rules and Consumer Duty.

The CCI Risk and Return Score is a standardised metric on a scale of 1 (lowest risk) to 10 (highest risk). The calculation method varies by product type:

In all cases, the score must be accompanied by a plain-English narrative in the Product Summary explaining what it means for the investor — not the number in isolation.

For standard products, the Risk and Return Score calculation requires 10 years of historical returns data at the share class level — either weekly or monthly, as specified in PS25/20. The data must be clean, validated, and consistent in currency and calculation basis.

For products with less than 10 years of history, the FCA permits the use of a proxy methodology — typically using a representative benchmark or comparable fund with a longer track record, subject to disclosure that a proxy has been used. For newly launched share classes with fewer than 12 months of history, a fallback rate (such as a fixed assumed return) may be applied.

The broader scale (1 to 10 vs 1 to 7) gives investors greater granularity in understanding relative risk across products. The removal of the credit risk component for standard products also simplifies calculation for most fund managers.

Yes. During the optional transition period — which runs from 6 April 2026 to 8 June 2027 — both the PRIIPs KID and the new CCI Product Summary are legally valid for UK retail distribution.

Investment managers can choose to transition product by product, or move their entire fund range to CCI at once. There is no obligation to complete the transition before 8 June 2027, but there is also no benefit to delaying beyond what is operationally necessary — early movers have more time to test, iterate, and refine their disclosures before the mandatory deadline.

CCI is not simply a document update — it requires changes to data infrastructure, calculation methodology, website architecture, distribution agreements, and monitoring processes. The eight practical steps are:

CCI sits within the FCA's Consumer Duty framework, which gives the regulator broad powers to act where firms are not delivering good outcomes for retail customers. Non-compliance with CCI could result in:

• Regulatory intervention — the FCA may require firms to withdraw products from retail distribution until compliant documentation is in place.
• Fines and sanctions — failure to comply with Consumer Duty obligations can result in significant financial penalties.
• Reputational damage — public censure for regulatory breaches in retail investor protection.
• Distribution disruption — UK platforms and distributors may refuse to distribute products without compliant CCI Product Summaries and machine-readable Core Information.

Kurtosys handles the full CCI pipeline in four steps, eliminating the manual effort at each stage:

Yes. The Kurtosys platform is CCI-ready now. The Stats Engine supports both CCI and PRIIPs calculation modes simultaneously, meaning investment managers can transition product by product during the optional transition period without disrupting their existing PRIIPs workflow for products not yet migrated.

Starting during the optional transition period — which opened on 6 April 2026 — gives investment managers time to configure and validate calculations, test Product Summary templates, iterate on digital fund page designs, and train teams before the mandatory June 2027 deadline.

To see the Kurtosys CCI pipeline configured around your specific fund range, request a demo.