Why the FCA is Changing the Rules on CCIs (And What They Actually Want)

If you’ve ever read a KID and thought, “Who is this actually helping?”, you’re not alone. From PRIIPs to UCITS KIIDs, the current product disclosure landscape for complex investments has been widely criticised for being too rigid, too technical, and frankly, too disconnected from how real people make decisions.

Enter the Consumer Composite Investment (CCI) regime.

In this article, we’re not going to explain what CCIs are (we’ve already covered that here), but why the FCA is replacing the current rules, and what kind of behaviour and communication they actually want to see from firms going forward.

If you’re in product, marketing, compliance, or legal and your work touches retail-facing investment products, here’s what you need to know.

A broken disclosure system

The existing European frameworks (like PRIIPs and UCITS KIID) were designed with good intentions: to make investment information standardised and comparable. But in practice, they’ve fallen short.

The FCA has pointed to three big problems:

• Rigid templates: One-size-fits-all designs leave no room for product nuance or clear explanation.

• Complexity and jargon: Consumers often struggle to interpret dense performance metrics or legalese.

• Lack of clarity:  Disclosures can be technically compliant, yet still fail to communicate risks or costs in a way that actually protects consumers.

  
  

The bottom line? The current rules aren’t working for firms or investors.

What the FCA actually wants

This is a key shift in regulatory mindset, from form-filling to outcomes.

The FCA’s core goal with the CCI regime is to promote good consumer decision-making. That means ensuring information is:

• Accurate: no misleading claims, omissions, or ambiguity

• Understandable: written in plain English, with clear risk explanations

• Comparable: using standardised metrics so consumers can weigh options

• Timely: up-to-date at key decision points, like onboarding or fund switches

They’re also building in flexibility. Unlike the rigid PRIIPs template, the new Product Summary allows firms to explain product features in a more contextual, narrative format, while still hitting required metrics.

What’s changing (and what’s not)

Some things will feel familiar: you’ll still need to disclose risk scores, cost breakdowns, and performance history. But the way you do it is changing.

Here’s what’s new:

• Risk scoring: All CCIs will be assigned a 1–10 risk score, based on volatility and complexity. Higher-risk products must explain why they score high and what that means for investors.

• Narrative explanations: Alongside standard graphs and figures, firms are encouraged to explain in plain terms what investors need to understand.

• Design freedom: No more mandatory templates. As long as key information is present and clearly structured, firms can design disclosures in a way that aligns with their brand and audience.

• Distributor responsibilities: The regime clarifies that both manufacturers and distributors have a role in ensuring consumers understand the product.

Going beyond disclosures

This isn’t just a job for the legal team.

Because the CCI regime touches everything, from onboarding journeys to sales materials and social media copy, it will require cross-functional coordination especially between product, compliance, and marketing.

For example:

• If you’re designing a fund for UK retail investors, you’ll need to plan the Product Summary early in the product lifecycle, rather than bolting it on at the end.

• If you’re running acquisition campaigns, you’ll need to check that claims, visuals, and CTAs all reflect the risk disclosures and summaries shown at the point of sale.

• If you’re in distribution, you may need to work with upstream manufacturers to ensure you’re presenting the most up-to-date version of a Product Summary.

  
  

The move towards better communication

Ultimately, the FCA is raising the bar. They want firms to explain complex products with the same care and clarity they’d use to explain them to a friend.

And that’s where many firms will need support: not in understanding the metrics, but in communicating them well.

At Zeyro, we help bridge the gap between regulation and actionable, practical guidance. We work with compliance, product, and marketing teams to design disclosures and approval processes that protect consumers and make sense to the people building them.

Interested? Get in touch today to discover how we can support you through the CCI regime.