Your PRIIPs KID process won’t get you to CCI compliance. The calculation is different, the document is different and the data obligations are new. With the deadline of 8 June 2027, we look at what investment managers really need to know about the Consumer Composite Investments regime (CCI), without the regulatory padding.
What CCI is
The FCA’s new UK retail disclosure framework, finalised in Policy Statement PS25/20 in December 2025. It replaces both the PRIIPs KID and the UCITS KIID with a single, flexible product summary document, and it’s mandatory for all UK retail fund distribution from 8 June 2027. The optional transition opened on 6 April 2026. Both formats are legally valid until the deadline. The FCA’s reason for replacing PRIIPs: KIDs were “dense, technical, and highly templated.” Most retail investors didn’t read them. Among those who did, most didn’t understand them. CCI replaces a rigid template with a principles-based framework including more design freedom and more accountability.
Four things that actually change
Compliance becomes interpretative
PRIIPs was procedural, a rigid process to follow the template. Under CCI, firms exercise judgement at every step to ensure disclosures are fair, clear and not misleading. There is no template to hide behind.
The risk calculation is different
The PRIIPs 1-to-7 summary risk indicator is replaced by a 1-to-10 risk and return score, calculated from 10-year annualised standard deviation. It’s a different methodology with different data requirements. Your existing SRI calculation does not transfer.
A machine-readable data file is now mandatory
This is the one most firms miss. Alongside every product summary, manufacturers must produce a machine-readable core information file, typically a CSV or XML, for distributors to ingest into their own platforms and sales journeys. Without it, your fund doesn’t appear or appears with gaps. Most CCI vendors don’t produce it.
Monitoring is a compliance requirement
Under Consumer Duty, producing the disclosure isn’t enough. Firms must evidence investors are genuinely consuming it, e.g. time on page, scroll depth, download rates. All of it counts.
Three things to do before June 2027
Start with your data
The risk and return score requires 10 years of clean, validated returns data per share class. Most managers find it lives across multiple systems with gaps. This takes time to fix. Start here, before anything else.
Use the transition window
The optional period is open now. Every month you wait is a month less to configure, test and iterate before the mandatory deadline forces everyone else to launch something untested. Starting late could cost you a lot.
Check your vendor produces the data file
A solution that only generates a product summary PDF hasn’t solved your distribution problem yet. Make sure you’re getting the machine-readable core information file too. Kurtosys exclusively offers this as part of the CCI offering, from the same pipeline, updated automatically.
For the full CCI compliance checklist and calculation methodology, read our CCI FAQ. Ready to see it automated for your fund range? Get a demo.
