CP24/30 is the FCA’s consultation on a new product information regime for consumer composite investments (CCIs), and it gives the clearest picture yet of what will replace the PRIIPs KID and the UCITS KIID in the UK. The FCA published it just before Christmas and responses are due by 20 March 2025, which leaves a fairly short window to shape the detail before the rules are set.
Where does CP24/30 come from?
The Government has long said it would replace the UK’s versions of the PRIIPs and UCITS disclosure rules with a domestic regime run by the FCA. The legislation to do that, the Consumer Composite Investments (Designated Activities) Regulations 2024, was made on 21 November 2024, and CP24/30 is the FCA’s first set of draft rules under it. All CCI product information rules will sit in the FCA Handbook.
The FCA is direct about its reasons for change. It says consumers often find today’s documents confusing or overwhelming, and that the rigid PRIIPs template, with methodologies that don’t work well for every product, can sometimes produce inappropriate information.
What’s in scope of CP24/30?
A CCI is, broadly, an investment whose returns depend on the performance of indirect investments. The draft rules list explicit inclusions, namely securities issued by funds (including closed-ended funds), structured deposits, products that are or embed a derivative, contracts for difference, insurance-based investment products and certain debt securities. Pension schemes, however, are excluded from the regime, along with ordinary deposits that aren’t structured.
The rules would apply to any firm that manufactures or distributes a CCI to UK retail investors. That includes overseas funds recognised under the Overseas Funds Regime, which means EEA UCITS sold to UK retail investors would follow the same rules as UK funds.
What is the FCA proposing in CP24/30?
At the centre of the proposals is a product summary that replaces the KID and KIID. Manufacturers would prepare a standalone, consumer-facing summary for each CCI distributed to UK retail investors. It would cover the investment objective and policy, risk, past performance, costs and charges, who prepared it and when, and whether the Financial Ombudsman Service and the FSCS apply.
The FCA wants to drop the fixed template and the three-page limit, so firms would be free to design the summary using layering, dashboards, plain language and graphics. Standardisation would be kept for the things consumers need to compare, and several of those are changing too:
- Risk scale: the PRIIPs 1 to 7 indicator would give way to a 1 to 10 scale based on volatility, with room to adjust the score where particular risks or features, such as a capital guarantee, mean the number alone would mislead.
- Past performance: a past performance graph covering up to 10 years, where available, would return, updated annually.
- Costs: the reduction in yield tables would be replaced by summary costs over a 12-month period, with performance fees and carried interest explained through narrative and examples.
- Machine-readable core information: manufacturers would publish the product’s core information in a machine-readable file for distributors and third-party providers. The FCA isn’t proposing a template for it, and firms could include other data, such as sustainability disclosures, in the same file.
Distributors would also take on a bigger role, because they could either use the manufacturer’s summary or build their own from the core information. Either way, they couldn’t sell or advise on a CCI without a product summary, and investors would receive the information early in their journey, with a copy in a durable medium at or shortly after the point of sale.
Finally, the FCA proposes a lower bar for “not retail”, with the minimum investment that takes a product out of scope falling to £50,000 from the £100,000 that the FCA says applies under PRIIPs today.
When would the new rules apply?
The FCA intends the regime to come into force when its policy statement is published, or shortly afterwards, with an 18-month transition. During that period firms could keep using existing KIDs and KIIDs or move to the new rules as soon as they’re ready, while closed-ended investment companies would have 12 months.
The draft transitional rules, along with the knock-on changes to other parts of the Handbook, will come in a separate consultation in early 2025. The FCA plans to publish final rules in 2025.
What it means in practice
Freedom of format might look like less work, but in practice it moves the difficult part from layout to data. Every product summary, whether you build it or a distributor does, has to draw on the same risk score, cost figures and performance history, and a machine-readable file makes any gap between them visible to everyone who reads it.
For investment managers selling the same fund in the UK and the EU, it also means running two disclosure regimes side by side: the PRIIPs KID for the EU and the CCI product summary for the UK, built on different risk and cost methods from the same underlying data, which is where automated production of regulatory documents from one governed data set starts to pay for itself.
The timeline
- 21 November 2024: the CCI legislation is made
- 19 December 2024: CP24/30 is published
- Early 2025: a further consultation on transitional provisions and consequential changes is expected
- 20 March 2025: CP24/30 closes
- 2025: a policy statement with final rules is expected
- After that: an 18-month transition, or 12 months for closed-ended investment companies
What should investment managers do now?
- Respond by 20 March, since the format, the risk scale and the machine-readable file are all open questions and evidence from practitioners counts.
- Test the new numbers by modelling the 1 to 10 risk score and the 12-month cost summary for a sample of funds to see what moves.
- Map your distributors, working out who will build their own summaries from your data and what they’ll need from you.
Where the KID was a fixed document, the product summary looks more like a set of governed data points that different firms will turn into pages, so the quality and consistency of that data is the place to start preparing.
At Kurtosys we help investment managers keep fund data governed, so the same risk, cost and performance figures flow into factsheets, regulatory documents, client reports and fund websites, and out to distributors in the formats they need. When the UK’s product summary arrives, that’s one data model feeding many outputs. If you’d like to talk through what CP24/30 means for your documents, get in touch.
Sources: FCA CP24/30: A new product information framework for Consumer Composite Investments, CP24/30 (PDF), The Consumer Composite Investments (Designated Activities) Regulations 2024 (SI 2024/1198), as at 1 January 2025.
About this article
This article reflects the position at 1 January 2025 and was checked against the primary sources available at that time. Thomas Bjerkén, our regulatory reporting and fund data specialist, joined Kurtosys after it was published and now looks after our regulatory content. The UK CCI regime has moved on since. For the latest position, see CCI: where the industry is in its implementation journey.
