CCI Regime Explained: What Are Consumer Composite Investments?

Responsible for launching, marketing, or reviewing investment products in the UK? Heads up: the FCA is proposing a brand-new disclosure regime for something called Consumer Composite Investments (CCIs). It’s a catch-all category for complex, bundled investments, and it’s going to impact how you communicate risk, costs, and performance to retail investors.

If you’re in product, compliance, legal, or marketing, and your firm sells any kind of packaged investment to UK consumers, this one's for you.

Whether you're dealing with funds, structured notes, crypto ETPs, or just trying to figure out if your product even counts as a CCI… this explainer will walk you through what they are, why the rules are changing, and what you need to prepare for.

We’ll discuss: 

• Why this matters

• What counts as a CCI

• Who needs to pay attention?

• Why the FCA is introducing the CCI regime

• Key features of the CCI regime

• Why this matters for your product, copy, and comms

• What to do next

Let’s start from the top.

Why this matters

In the UK’s retail investment landscape, the rules are changing. The Financial Conduct Authority (FCA) has launched a consultation (“CP 24/30”) on a new regime designed to simplify how complex investment products are described to consumers.

If your product depends on the performance of underlying investments rather than the consumer directly owning them, you may be dealing with a Consumer Composite Investment (CCI).

CCI defined

A CCI is an investment where the returns (what the consumer earns) depend on how other investments (which the consumer does not hold directly) perform.

In other words: product A is made up of or derives value from product B, C or more.

What counts as a CCI?

The FCA gives a broad definition and a list of examples.

Explicit products include:

• Structured deposits

• Securities which embed derivatives or equivalent features

• Debt securities with certain features

• Rights to or interests in securities issued by funds

• A security issued by a closed‑ended investment funds

• A contingent convertible security

• A contract for difference (CFDs)

• Insurance‑based investment products (IBIPs)

The FCA’s draft rules also include explicit exclusions, such as pension products and pure protection contracts of insurance.

Who needs to pay attention?

 If you manufacture (design, issue, operate) or distribute (offer, sell, advise) a retail product in the UK that falls within the definition of a CCI, the regime will apply.

This covers: UK‑authorised firms and, in some cases, overseas manufacturers/distributors marketing into the UK.

CCI regime timeline: from policy reform to product disclosure

The story of the CCI regime starts with the UK government’s Edinburgh Reforms in December 2022, which was a broad policy initiative that signalled a desire to create a more flexible, UK-specific disclosure framework for retail investments. This set the wheels in motion for the FCA to begin rethinking how complex investment products are explained to consumers.

In November 2024, the legal foundations were laid with the publication of the Consumer Composite Investments (Designated Activities) Regulations 2024, establishing the regulatory category of “CCI”. Just a month later, in December 2024, the FCA published its first consultation paper (CP24/30) proposing the core rules and structure of the new disclosure regime - including the concept of a “Product Summary” to replace legacy documents like the KID or KIID.

Next, the FCA launched a second consultation in April 2025 (CP 25/9) to address key areas such as transaction cost calculations and transitional provisions. That consultation closed in May 2025, marking the end of the formal feedback period. 

Now, we’re waiting for the final rules. The FCA is expected to publish a policy statement later in 2025. Firms can expect a window stretching into 2026 and beyond, giving time to align internal systems, redesign disclosures, and coordinate across product, marketing, and compliance teams. 

TLDR? The regime is coming, and while the ink isn’t dry just yet, the outlines are clear. If your firm manufactures or distributes investment products to UK retail clients, this is your opportunity to prepare ahead of the curve.

Why the FCA is introducing the CCI regime

The current disclosure frameworks (such as those for PRIIPs or UCITS) have been criticised for being overly rigid, containing complex templates, and not always helpful to the average consumer.

The FCA’s goal is to promote information that is accurate, understandable, comparable and timely, so that consumers make better decisions and firms can communicate more effectively.

Key features of the CCI regime

 Here are some of the key features under the proposed CCI regime:

• A new document: the Product Summary, replacing legacy KIDs/KIIDs.

• Standardised metrics (costs, risk, performance) plus narrative explanation.

• A risk score on a 1‑10 scale, reflecting volatility and other risk factors.

• Clear breakdowns of costs: entry, ongoing, exit, transaction.

• Emphasis on distributor‑manufacturer cooperation and information flow.

Why this matters for your product, copy and comms

The CCI regime goes far beyond a disclosure exercise, as a sizeable shift in how firms are expected to communicate. That means product, marketing and compliance teams need to consider:

• For product development teams, the structure, risk profile, and cost layers of your products must be crystal clear - not just internally, but to retail audiences.

  
  

• For compliance and legal, the new rules offer more flexibility, but also introduce judgment calls around what’s “clear” or “comparable”. You’ll need updated frameworks for approvals and internal QA. 

  
  

• For marketing and comms, the FCA is watching how you explain these products, across every touchpoint: landing pages, onboarding flows, summary docs, and even pitch docs. 

  
  

If you distribute through partners or platforms, coordination becomes even more important. Distributors will carry their own responsibilities under this regime - and misalignment between your materials and theirs could create risk, conclusion, or friction.

What to do next

Getting ahead of this now will save your teams from rushed rewrites and regulatory red flags. Here’s how to get started:

• Review your product range: does any product depend on underlying investments you don’t directly hold?

• Identify affected stakeholders: product teams, legal/ compliance, marketing and distribution partners.

• Start thinking about your current documentation: product summaries and whether they will meet the “accurate, understandable, comparable” standard.

• Monitor the consultation timeline: Final rules are expected in 2025 with transitional provisions.

  
  

Support with the CCI regime

The CCI regime isn’t just another regulatory refresh… It’s a seismic shift in how firms communicate complex investments. The FCA wants disclosures that are as clear as the products are intricate, and that means marketing, product, and compliance teams need to work together earlier and more intentionally than ever before.

If you design, promote, or approve investment products in the UK, now’s the time to review your approach. The consultation period is your window to prepare, test, and align.

At Zeyro, we help teams translate regulatory frameworks like CCI into communication strategies that make sense, for firms and for investors.

Get in touch to discover how we can help you flourish amidst the CCI changes.