Since the CCI optional transition opened on 6 April 2026, we’ve been talking to investment managers across the UK.
Surprisingly, the person in on the call typically isn’t from compliance. It’s the CMO.
Not because marketing owns CCI. It’s because everyone else hit a roadblock, and it escalated. Compliance flagged it. Operations said it needed new infrastructure. Technology said it needed a brief. Six months later, nobody had written the brief. So it landed with the person who can force a decision.
If that sounds familiar, you’re not alone. But the clock is running.
The problem nobody planned for: it’s going to look dull
Ask a marketing director what CCI output they’ve seen so far. The word that comes back, consistently, is ‘dull’.
That might seem like a superficial concern, but in fact, it’s the whole problem CCI was designed to fix. The FCA’s own research found that 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 the rigid KID template with something principles-based and flexible. That’s an opportunity. But the firms approaching CCI as a compliance exercise are producing something that looks exactly like what they replaced. And the firms approaching it as a marketing problem are producing something that hasn’t been stress-tested for regulatory robustness.
Neither is good enough. And the firms that get it right will build a genuine competitive advantage, because CCI is the first time retail investors can compare your risk score, your costs, your performance against every other manager’s, side by side, on any platform, without asking anyone.
What your disclosure looks and reads like matters more than it ever has.
Three things that are blocking most firms right now
The data isn’t as clean as you think. The CCI risk and return score requires 10 years of validated returns data at the share class level. In almost every conversation we have, the assumption going in is that this data exists and is accessible. By the second conversation, it turns out it lives across three systems, has gaps where funds have been restructured, and hasn’t been validated against the calculation methodology PS25/20 requires. Start with data architecture. Everything else depends on it.
The auditors’ position is unclear. Across our conversations with asset managers, we’re hearing that they have gone to their auditors asking whether CCI calculation numbers, specifically the risk and return score, need independent sign-off before publication. The consistent response: silence. That’s a material unknown sitting unresolved in the middle of live implementation plans. If your auditor hasn’t confirmed their position, that conversation needs to happen now.
Institutional share classes are (unnecessarily?) being caught in scope. For managers with large fund ranges registered under the overseas funds regime, institutional share classes sitting within those funds are landing in CCI scope by default, even where they’ll never reach a retail investor. The FCA hasn’t addressed this directly. The wrong answer creates unnecessary work across hundreds of share classes. Get clarity early.
The firms getting this right started differently
In our pipeline, the investment managers making the best use of the optional transition period do three things differently.
- They separated the design conversation from the compliance conversation on day one. Compliance answers what has to be in the product summary. Marketing answers what it should look like and how it should communicate. Different briefs. Different people. Don’t conflate them.
- They started with one fund. Not their whole range, just one fund, one share class, end to end. Calculation validated. Template designed. Data pipeline confirmed. Document generated. Hosted on the fund page. Then they scaled. The managers trying to solve CCI for 200 share classes simultaneously are the ones still in gap analysis mode.
- And they’re treating the product summary as a floor, not a ceiling. The FCA’s layering principle: most critical information first, detail accessible below, is an invitation to build a better investor experience than the KID ever was. The managers who get this are already testing interactive fund pages and plain-language risk narratives. They’ll have iterated before the deadline forces everyone else to launch something untested.
June 2027 arrives for everyone. What it finds you with is your call.
The moment things shift in every CCI conversation we have is when a marketing director sees what a properly designed, data-driven product summary actually looks like. Layered. Branded. Built to what the FCA actually asked for, not just its minimum requirement.
That window is open now. It won’t stay open.
The firms getting CCI right aren’t solving a document problem. They’re focused on solving the underlying data problem, and using the answer to publish the right information, in the right format, to every channel that needs it simultaneously.
That’s what Kurtosys does. One source of clean, validated fund data. One calculation engine built to PS25/20. One workflow that produces your product summary PDF, your machine-readable core information file, your interactive fund page, and your distributor data feed. At the same time, from the same data, without manual intervention at any step.
To see it built around your fund range, get a demo or explore our CCI compliance page.
Glossary of CCI terminology:
CCI (Consumer Composite Investment)
An investment where returns depend on the performance of an underlying asset such as a fund, structured product, or contract for difference. The CCI regime is the FCA’s new UK-specific disclosure framework, replacing the previous EU-derived PRIIPs and UCITS rules.
Product Summary
The consumer-facing disclosure document manufacturers must produce under the CCI regime. It must include costs, risk and return score, past performance, and product features,written in plain language and published on a publicly accessible website.
Core Information File
The machine-readable data file that sits behind the product summary. It contains standardised costs, risk, and performance data in a structured format (such as CSV) so distributors can access and display it across their platforms.
Risk and Return Score
A standardised metric that is required in every product summary and gives retail investors a comparable view of a fund’s risk profile and expected return. It must be calculated using 10 years of validated returns data at share class level.
PRIIPs KIDs (Key Information Documents)
The disclosure documents that CCIs replace. Introduced under EU regulation, KIDs were widely criticised for being dense, overly templated, and poorly understood by retail investors — the problem the CCI regime was designed to fix.
FAQs:
- When does CCI come into effect, and do we need to act now?
The optional transition period opened on 6 April 2026, with the full deadline of June 2027 applying to everyone. Acting during the transition window gives you time to iterate and refine before you’re forced to launch something untested. - Which share classes fall under CCI scope?
This is still an area of ambiguity. For managers with funds registered under the overseas funds regime, institutional share classes within those funds may fall into CCI scope by default;even if they’ll never reach a retail investor. Getting clarity from your legal or compliance team early prevents unnecessary work across potentially hundreds of share classes. - What data do we need, and is ours ready?
CCI requires 10 years of validated returns data at the share class level. In practice, this data often lives across multiple systems, contains gaps from fund restructurings, and hasn’t been validated against the PS25/20 calculation methodology. Auditing your data architecture is the right first step. - Does our risk and return score need independent sign-off before publication?
This remains unresolved for many firms. Auditors are not yet giving clear guidance on whether CCI calculation figures require independent verification before publication. Firms should raise this with their auditors now rather than discovering it mid-implementation. - Who should own CCI — compliance or marketing?
Both, but separately. Compliance should define what must be included in the product summary; marketing should own how it communicates and looks. Conflating the two briefs is one of the most common reasons implementations stall. The firms making the most progress have kept these workstreams distinct from day one. - What solutions are available for CCI compliance? Firms are either building in-house, stitching together existing tools, or working with a specialist platform. The first two can produce a PDF. They typically can’t handle data validation, PS25/20 calculation, and multi-channel output at scale.
Kurtosys is purpose-built for this. Our CCI solution covers the full workflow: data ingestion and validation, risk and return score calculation to PS25/20, product summary design and generation, Core Information File production, fund page publishing, and distributor data feed distribution – all from a single source of fund data, without manual intervention at any step. For investment managers with large fund ranges, that’s the difference between a compliant, maintainable CCI programme and a one-time document exercise that breaks the moment something changes.
For more information on CCI, visit the official site.
