UK CCI: Preparing for the New Disclosure Requirements

 Author: Roger van den Berg, November,  2026

The UK’s Consumer Composite Investments (CCI) regime introduces a new approach to retail investment product disclosures, replacing existing requirements for the PRIIPs regime and the UCITS disclosure requirements with a single framework tailored for UK consumers and markets..

For investment managers, management companies and product manufacturers, the transition presents both regulatory and operational considerations. Firms will need to assess their existing disclosure processes, prepare for new product summary requirements and establish appropriate governance arrangements to support ongoing compliance.

Understanding the UK CCI Regime

The Financial Conduct Authority (FCA) published its final rules for the CCI regime in December 2025, establishing a new framework designed to improve how retail investors receive and understand information about investment products.

Under the new regime, manufacturers must prepare product summaries that communicate essential information about an investment, including its characteristics, risks, costs and potential returns.

The framework provides greater flexibility in how information is presented while maintaining standardized requirements for key disclosures, supporting greater transparency and informed investment decisions.

Key changes include a new 1–10 risk and return scale, replacing the previous 1–7 scale, and requirements to present past performance, where available, through a line graph to help investors understand how the investment has performed over time.

Key Implementation Dates

The CCI regime includes a transitional period to allow firms to prepare for the new requirements.

  • December 8, 2025: FCA publishes its final CCI rules.
  • April 6, 2026: Transitional period begins, allowing manufacturers to adopt the new product summaries or continue using existing disclosure documents.
  • June 8, 2027: Full implementation of the CCI regime, with firms in scope required to comply with the new framework.

While the transitional period provides flexibility, firms should use this time to assess their existing processes and identify the operational changes required ahead of full implementation.

Key Considerations for Investment Managers

Product Summary Preparation
Investment managers acting as product manufacturers will need to review their existing disclosure documentation and determine how product information should be presented under the new framework. This includes assessing data requirements, document structures and the processes used to prepare and validate disclosures.

Data Quality and Consistency
Accurate and consistent source information remains essential. Manufacturers should review how product data is collected, checked and kept up-to-date to support reliable disclosures across products and share classes.

Governance and Oversight
Investment managers should establish clear responsibilities, documented approval processes and effective quality controls for their role in the disclosure lifecycle. Defined workflows help maintain consistency and support effective oversight and accountability.

Ongoing Monitoring and Updates
Disclosure obligations extend beyond initial document production. Investment Managers acting as product manufacturers must ensure product summaries are reviewed regularly and updated where necessary processes supporting periodic reviews and event-driven updates, including changes to product characteristics, underlying data and regulatory requirements.

Preparing for the Transition

With the implementation deadline approaching, firms should review their existing disclosure arrangements to identify potential gaps and operational dependencies.

Key preparation activities include:

  • Assessing existing disclosure documents against the new requirements.
  • Reviewing source-data availability, quality and validation processes.
  • Establishing appropriate governance, review and approval procedures.
  • Evaluating internal resources and operational capacity.
  • Developing structured processes for recurring reviews, updates and document management.

Taking a structured approach to implementation can help reduce operational complexity and support a more consistent disclosure process.

How DM Financial Can Support

Product Summary DM Financial provides specialist Investor Disclosure Services to investment managers, management companies and product manufacturers across multiple regulatory frameworks, including UK CCI, PRIIPs and UCITS.

Our services cover disclosure document preparation, data review, governance and quality controls and ongoing lifecycle management.

Combining specialist financial and regulatory reporting expertise with structured workflows and experienced oversight, we help firms manage their investor disclosure requirements efficiently while maintaining control and transparency.

Meet the Author