PS25/20, the FCA’s final rules for Consumer Composite Investments published on 8 December 2025, keeps the broad shape of the 2024 consultation but changes several details that land squarely on the numbers and data manufacturers will have to produce. Consumer Composite Investments (CCI) is the UK regime replacing the PRIIPs KID and the UCITS KIID for retail investors, and below we set out what moved and the dates to plan around.
Where does the CCI regime come from?
The government’s legislation, the Consumer Composite Investments (Designated Activities) Regulations 2024, sets up the regime and ties it to the revocation of the UK’s inherited PRIIPs law under the Financial Services and Markets Act 2023. The FCA consulted on its rules in CP24/30 in December 2024 and on further proposals in CP25/9 in 2025, and PS25/20 responds to both and makes the final rules, in a new DISC sourcebook in the Handbook.
The core idea hasn’t changed, so manufacturers still produce a product summary, and while they have considerable freedom over its design, the key figures for costs, risk and return, and past performance are standardised so that consumers can compare products.
What did PS25/20 change on costs?
Costs are where the FCA moved furthest from its original proposals.
In CP24/30 the FCA wanted explicit and implicit transaction costs aggregated into a single summary cost figure. Respondents pushed back, and the FCA agreed that one-off costs don’t belong in a 12-month figure, so the final rule is that the ongoing costs figure must be presented as the headline. Explicit transaction costs and one-off costs are still disclosed, but they aren’t added in.
Implicit transaction costs have gone altogether, as CP25/9 had already proposed and PS25/20 now confirms. Explicit transaction costs must be shown as a number, separately from ongoing costs, and the FCA gives firms flexibility over where they sit on the product summary, while treating mark-ups and mark-downs as explicit costs.
There are several other changes on costs:
- Investment trust costs aren’t pulled through: for funds investing in closed-ended investment funds, the underlying costs must be disclosed but won’t be added to the investing fund’s ongoing costs figure. Costs of other underlying CCIs are still pulled through into a synthetic figure, and the FCA dropped its earlier idea of exempting passive funds from that.
- Gearing and real asset maintenance are out: no CCI has to include them in its ongoing costs.
- Short-dated structured products show lifetime costs: where maturity is under a year, costs are shown over the product’s life, and cost figures are still shown in pounds and pence, even for non-sterling products.
What changed on the risk score?
The risk and return score moves from the 1 to 7 scale used under PRIIPs to a 1 to 10 scale, as proposed, which most respondents supported because it reduces bunching.
The volatility calculation now uses 10 years of returns instead of five, giving it a longer look-back. The FCA has also amended its policy so that illiquidity raises the score by at least one point.
What changed for distributors?
Distributors can’t create their own product summaries or change a manufacturer’s, and they must make the summary available before a sale and give it in a durable medium afterwards. Manufacturers, in turn, must give distributors the underlying information in a machine-readable file, unless they’re the only distributor of their own products.
When do the CCI final rules apply?
- 21 November 2024: the CCI Regulations are made
- December 2024: the FCA consults in CP24/30
- 2025: the FCA publishes further proposals in CP25/9
- 8 December 2025: the PS25/20 final rules are published and the 18-month implementation period begins
- 6 April 2026: the legislation commences and firms can start using the new regime
- 8 June 2027: the regime is fully in force and in-scope firms must have moved across
Until 8 June 2027, the FCA says manufacturers can choose between producing a product summary and continuing their current arrangements, so existing KIDs and KIIDs remain usable through the transition.
What to do now
- Re-run your cost numbers, because the ongoing costs figure is now the headline, implicit costs are out and explicit transaction costs stand alone, so it’s worth checking what your data can actually produce.
- Rebuild the risk score, since 10 years of history and an illiquidity uplift mean new calculations, and possibly proxy data for younger funds.
- Agree the data file with your distributors, because the machine-readable feed matters as much as the document and has to match it exactly.
The final rules are more practical than the consultation and in places much simpler for consumers, although that doesn’t necessarily mean less work for manufacturers. The 18-month implementation period gives enough time to do this properly, provided the work on costs, risk and data starts early in 2026.
At Kurtosys we see CCI as a shift from filling in a template to owning the numbers behind a document. When governed fund data feeds the product summary and other regulatory documents, the distributor data file, factsheets and fund websites from one source, the figures agree everywhere and every change has an audit trail. If you’re planning your CCI programme for 2026, get in touch.
Sources: FCA PS25/20: Supporting informed decision making: Final rules for Consumer Composite Investments, PS25/20 (PDF), The Consumer Composite Investments (Designated Activities) Regulations 2024, SI 2024/1198, FCA CP24/30, FCA CP25/9, as at 1 January 2026.
About this article
This article reflects the position at 1 January 2026 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.
