The point of a retail disclosure document is that an ordinary investor can lay two of them side by side and tell which product is riskier and which is cheaper. That is the entire promise. So the most consequential line in the FCA’s new disclosure regime is not a rule about content — it is the clause that lets firms ignore the new format for more than a year.
The Consumer Composite Investments (CCI) regime replaced the onshored PRIIPs Regulation, and the UCITS KIID alongside it, when the legislation commenced on 6 April 2026. But commencement did not switch the old documents off. The FCA built in an optional transition: from 6 April 2026 a manufacturer may produce the new CCI product summary, or it may carry on issuing the PRIIPs KID or UCITS KIID it already produces. The new summary becomes mandatory only on 8 June 2027.
For roughly 14 months, then, the UK retail-investment shelf holds two different disclosure documents for economically similar products. That is the story. The reform is sensible. The interim is the problem.
What the new document actually is
PRIIPs failed in the UK for a specific reason: it was a rigid template imported from Brussels that produced numbers retail investors found misleading — most notoriously its performance scenarios and its summary risk indicator. The CCI regime’s answer is to keep standardisation where comparison depends on it and throw out the prescriptive form everywhere else.
There is no prescribed template and no page limit. A manufacturer designs the layout, the length, and the presentation of its product summary. What the FCA fixes is the content that must appear and the way certain figures are calculated, so that the comparable parts stay comparable:
- Product features — name, unique identifier, investment objective and strategy, recommended holding period, exit fees, redress availability, and, for fund CCIs, authorisation status and the operator’s name.
- A risk-return score on a 1–10 scale, anchored to volatility, sitting beside a narrative risk explanation rather than standing alone as PRIIPs’ bare indicator did.
- Costs — all direct and indirect charges, split into ongoing, one-off and transaction costs, under detailed calculation and presentation rules.
- Past performance — a standardised line graph over ten years (or the available history), built on a £10,000 initial investment, with benchmark information where it applies.
The design intent is coherent. Free firms to communicate clearly, but lock down the four things — features, risk, cost, performance — that an investor needs to hold constant when comparing one product against another. On its own terms it is a better regime than the one it replaces.
The two-track gap
The trouble is that “comparable parts stay comparable” assumes both products in front of the investor speak the same language. During the transition, they will not.
Picture two competing equity funds on the same platform in, say, October 2026. Manufacturer A has moved early and ships a CCI product summary: a 1–10 volatility-anchored risk-return score, costs in the new three-way split, a ten-year £10,000 performance graph, all in a format of A’s own design. Manufacturer B has used its right to wait and still ships a UCITS KIID: the old 1–7 summary risk indicator, the legacy cost presentation, the prescriptive layout. The investor is now comparing a risk score out of ten against a risk score out of seven, costs computed under two different rulebooks, and two performance presentations built to different conventions.
The headline numbers no longer line up. The reform that was justified as supporting informed decision making — that is the literal title of PS25/20 — produces, for 14 months, exactly the apples-to-oranges comparison it was meant to end. Comparability is not improved during the interim. It is suspended, and arguably it is worse than under PRIIPs alone, because at least PRIIPs was uniformly bad in the same way for everyone.
This is a direct consequence of giving firms discretion over whether to switch, not just how to present. An optional transition is the humane choice operationally — systems, data pipelines and cost calculations take time to rebuild — but it externalises the cost onto the one party the regime exists to protect.
What manufacturers will actually do with the freedom
The interesting question is what asset managers do with the design latitude once they cross over. Two pressures pull against each other.
The first is differentiation. A manufacturer that genuinely believes its product is well-suited to a retail investor now has room to say so clearly — plain-language objectives, an honest narrative on risk, presentation that does not bury the recommended holding period. The better firms will treat the product summary as a communication asset rather than a compliance artefact, which is precisely what the FCA hoped for.
The second pressure is convergence, and it is stronger. The moment one large platform or fund group settles on a house style for the CCI summary, the rest face pressure to mirror it — because a distributor showing ten summaries side by side wants them to look comparable, and because no compliance team wants to be the outlier when the FCA reviews the market. “Freedom to design” tends, in practice, toward a de facto industry template that emerges from the largest manufacturers and the dominant platforms rather than from a regulator’s annex. The format will standardise; it will just standardise privately, and a year or two later than a prescribed template would have.
There is a sharper near-term cost the design freedom does not touch. The FCA has given no indication it will exempt the CCI product summary from the financial promotion regime, unlike the carve-out PRIIPs KIDs enjoyed. A firm-designed, free-format document that doubles as a financial promotion carries promotion-rule liability the old prescriptive KID did not — a particular burden for unauthorised manufacturers who must now route their summaries through the promotion regime. Freedom of format is not freedom of consequence.
The distributor pass-through
One structural choice limits the damage. Distributors are not required to assess whether a manufacturer’s product summary meets investor needs; they must make the unamended summary available and encourage investors to engage with it, with an exemption for execution-only brokers and platforms. That keeps responsibility for the document with the firm that built the product — correct in principle, and it avoids a second layer of interpretation sitting between the manufacturer and the investor.
But pass-through also means the platform does nothing to reconcile the two-track gap. It hands the investor whatever document the manufacturer chose to produce, old format or new, and the work of translating a 1–7 indicator into a 1–10 score falls on the person least equipped to do it.
The window closes on its own
The honest read is that the CCI regime is an improvement that will deliver its benefit on 8 June 2027 and not meaningfully before. Until then, the optional transition produces a retail shelf where the disclosure document depends on how fast each manufacturer’s operations team moved, not on the product. Early movers gain little — their better summary sits next to a legacy KID and cannot be compared cleanly. Late movers carry the old cost the reform was meant to remove. And the investor the regime is built for spends 14 months reading two languages.
The reform is right. The runway is the price, and it is the investor who pays it.
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