Our recent Consumer Composite Investments (CCI) regulation webinar gave us a clearer picture of where firms currently stand. In our poll, 87% of attendees said they are still planning their approach rather than actively implementing it, with only a small number of firms further along in their journey. This reflects the scale and complexity of the work involved, and the fact that many firms are taking a considered approach before committing to a direction.
Where is your firm in its CCI transition journey?
For most firms, understanding the rules is not the main challenge. The real work lies in translating those rules into practice: mobilising internal teams, interpreting the FCA’s principles-based requirements, and building in time for proper testing and feedback.
Julia Sage-Bell from PIMFA explained that firms are progressing at different rates depending on their business model, product range and distribution approach. Larger firms often have more resources to draw on, though they also tend to have more products, stakeholders and governance processes to coordinate. Firms with simpler product ranges, or more vertically integrated models, can sometimes move through the process more quickly as a result.
Distributors have their own particular considerations. They are building new customer journeys without always having the final product summary documents available yet, so many are focusing on establishing solid foundations for day one, with further refinement of the customer journey planned afterwards.
How one asset manager is approaching implementation
Matthew Huntington from Ninety One shared how his team has structured its implementation. They brought together product, legal, compliance, operations and client teams early in the process, and chose to continue working with their existing key investor information document (KIID) supplier rather than starting from scratch. They also decided to replace KIIDs with product summaries at share-class level, rather than creating a single fund-level summary across different share classes.
Consumer testing has been an important part of shaping the right approach. Matthew described the process of finding the right balance between clear, concise information and the level of detail firms have traditionally included in regulatory disclosures. Sustainability information, for example, can run to more than 20 pages in prospectus documentation, and needs to be communicated in a much more accessible way within the product summary.
The panel agreed that product summaries should be designed around what investors actually need to know. This means making important information easy to find, keeping the document free of dense legal text, and considering how it reads for an ordinary retail investor. Matthew’s team is testing elements such as an at-a-glance section, fund objectives, ongoing charges and performance information, while placing more technical explanations in a glossary.
Considerations for overseas managers
Jessica Reed from Burges Salmon highlighted a specific consideration for overseas managers. Under the UK Financial Promotions regime, the CCI product summary is treated as a financial promotion, which means it needs to be produced or approved by an appropriately authorised UK entity. This is an important factor for overseas managers to plan around if they do not have a UK presence.
Where firms are looking for further clarity
Some terms within the regulation, such as what is considered “reasonable”, how much time is sufficient to review a document, and how firms should evidence engagement, leave room for interpretation. Julia’s advice was for firms to consider their own business model, target market and customer profile, document their rationale, and take those decisions through appropriate governance.
The FCA’s transitional period is also shaping implementation plans. Until 7 June 2027, manufacturers choose product by product between a product summary and their existing KIID, so distributors will be handling both side by side. Funds still on a KIID face the usual February update, which is why many firms plan to switch before mid-February 2027 and avoid two document production runs. Firms are also working through how to keep data points consistent as fund and share-class information changes across different documents.
Matthew also spoke to the importance of the machine-readable data that manufacturers must make available to distributors, and the role FinDatEx templates will play in carrying it. FinDatEx is adapting its European MiFID and PRIIPs templates for CCI, with revised versions expected in early 2027. That timing is one reason Ninety One is staying on the KIID for now. Switching before the industry data standard is settled would mean supplying distributors with data that may need reworking later.
Looking beyond June 2027
The panel expects meaningful work to continue after the deadline, as firms use consumer testing and feedback to refine their documents and customer journeys further. There is also likely to be more focus on the FCA’s ambition for interactive and dynamic journeys, as well as how CCI requirements fit alongside other regulatory developments, including the new costs and charges regime.
For investors, this is likely to mean a wider range of product summary formats over time. The panel emphasised the importance of consistency in the core information presented to investors, particularly through distribution platforms and non-advised journeys. Advisers may have more scope to add context and explanation, while firms operating digitally will need to think carefully about how information is presented throughout the customer journey.
Overall, the panel’s message was one of steady progress. Firms should focus on getting the fundamentals right, documenting their decisions, and testing what they produce with real consumers. June 2027 is a significant milestone, and for many firms, it will mark the beginning of an ongoing process of testing, refinement and building better consumer journeys.
