UK CCI Problem Architecture Features Use Cases Security Blog Log in Request Demo
UK CCI · FCA 2025/52 · Engine Built

The UK CCI clock
is already running

The FCA's Consumer Composite Investments regime replaces UK PRIIPs KIDs and UCITS KIIDs. The first transitional provisions expire on 1 January 2027; the full regime lands on 8 June 2027. Kairo's CCI engine is built: classification, DISC risk and cost calculations, product summaries, and the evidence trail behind every number.

Book a CCI Readiness Assessment See the CCI Engine

UK Consumer Composite Investments

CCI, handled end to end

FCA 2025/52 rewrites UK retail disclosure: new documents, new calculations, new record-keeping duties. Kairo runs the whole chain, from source data to evidenced disclosure.

2025
FCA 2025/52 made. The Consumer Composite Investments Instrument becomes law and the DISC sourcebook is created.
5 APR 2026
Legacy rules frozen. UK PRIIPs and KIID requirements are locked as a frozen ruleset for the transition. No more updates; only the way out.
1 JAN 2027
Transitional windows start closing. The first transitional provisions expire. Firms still on legacy documents lose room to manoeuvre.
8 JUN 2027
Full regime in force. Every in-scope product needs CCI disclosure. The KID production line is legacy.

What changes

New documents

The PRIIPs KID and UCITS KIID give way to the CCI product summary under the FCA's DISC sourcebook. New content, new format rules, new distribution duties.

New calculations

A 1–10 risk score from a 10-class annualised-volatility grid, with floors and documented adjustments. Cost disclosure built from transaction history and contractual charging terms. Different maths from the SRI you run today.

New record-keeping

Judgement calls the regime allows, like a risk adjustment or a representative share class, must be recorded, justified, and approved by a named person. Evidence is part of the disclosure, not an afterthought.

What the Kairo CCI engine does

Eligibility classifier. Every fund, share class, and date resolves to exactly one outcome with named reason codes. No guessing which products are in scope.
DISC risk engine. The 10-class volatility grid, score floors, the low-liquidity uplift, and governed adjustments, computed from weekly pricing by the book.
Cost disclosure. Transaction costs over the regime's windows, entry and exit charges from contractual charging terms, and the regime's inclusion rules applied.
Product summaries. Rendered per share class in HTML, CSV, JSON, and PDF; sealed and reconciled so every output says the same thing.
Controlled facts. Every regulatory input is a versioned, approved fact with a source and effective dates. Unknowns block; they never default.
Human governance. Named approvers with recorded authority and separation of duties. The platform computes and evidences; it never approves its own disclosures.
Evidence packs. A generated pack maps every regulatory case to the tests that prove it, from real runs. Show your work, automatically.
Readiness report. One screen per client: the go-live preconditions, your whole book classified, and every blocker named with its fix.
Governance by design: nothing releases without a recorded human approval. The engine computes, renders, and evidences; your named approvers decide. That is the posture the regime demands, built in rather than bolted on.
Book a CCI Readiness Assessment

The regulatory backbone of every pipeline

Every field Kairo normalises maps to an industry standard. Every output complies with a regulatory template. This isn't decoration — it's the foundation.

1,800+
Openfunds Fields
600+
EET data points
9
Regulatory frameworks
v4.2
Latest EMT version

The Problem

Fund data is painful

Every fund administrator, asset manager, and data platform deals with the same broken workflow.

!

Dozens of formats, zero consistency

CSV, XLSX, JSON, PDFs. Every provider sends data differently. Manual mapping takes days per source.

The Openfunds mapping challenge
~

Silent data quality issues

NAVs that don't match, stale prices, missing ISINs. Problems surface when a client calls. By then it's a fire drill.

Catching discrepancies across sources
<>

Manual delivery is fragile

Outbound data formatted by hand, sent via email, with no confirmation it arrived. Publication matrices live in spreadsheets.

Why pub matrices belong in code

Watch fund data flow through the pipeline

Click any stage to explore. Real data types, real transformations, real field IDs.

Receive
Ingest
Map
Store
Quality
Format
Deliver
Receive Files and API feeds arriving from asset managers
0 files ingested 0 issues flagged 0 records delivered

Built by people who've done this at scale

We didn't start with a whiteboard. We started with a production system.

The Kairo team designed and built an enterprise fund data platform that ran in production at one of Europe's largest fund data service providers.

That internal platform handled data acquisition from hundreds of sources worldwide — CSV, Excel, JSON, PDFs, databases, APIs. It automated staging, mapping, integrity checking, transformation, and publishing across the full value chain.

It supported multi-format ingestion, proactive data integrity checking, automated error handling, and downstream publishing — at enterprise scale with hundreds of clients and thousands of funds.

Kairo is the next generation. We took every lesson from operating that system — what worked, what broke, where humans got stuck — and rebuilt it with AI-powered pipeline construction, deterministic locked execution, cross-source quality detection, and an agent-first architecture designed for 2030.

What we learned at enterprise scale
100s
Data sources
1000s
Funds processed
7+
Years in production
EU-wide
Multi-jurisdiction

Proven at scale

Multi-format ingestion Automated mapping Integrity checking Data transformation Publishing Error handling Client onboarding Regulatory filing

Architecture

Five domains, one data flow

Purpose-built for fund data. Each domain does one thing well and communicates via an event spine. Why five domains, not twelve services

1

Ingest

Receive and store raw data from any channel

UploadSFTPEmailAPI
2

Process

AI-mapped pipelines with deterministic execution

AI MapperNormaliseOpenfunds
3

Quality

Validate, detect anomalies, compare cross-source

RulesAnomaliesCross-source
4

Deliver

Format, route, and reconcile outbound data

SFTPAPIPub Matrix
5

Agent

8 specialist AI agents with human-in-the-loop

AtlasArgusHermes+5
Event Spine data.received data.processed quality.issue deliver.sent agent.needs_human Why an event spine, not REST
5
Core Domains
8
Specialist Agents
0
AI in Execute Path
<5min
File to Normalised

Meet the Agents

8 specialists. One platform.

Each agent owns a domain. They work autonomously, escalate on exceptions, and write the build log. Agent-first, not dashboard-first

A

Atlas

Mapper

Maps source fields to Openfunds. Builds pipelines with confidence scores. Owns normalisation.

Ar

Argus

Quality

Validates every field. Detects anomalies, cross-source discrepancies, and regulatory gaps.

H

Hermes

Delivery

Routes data to destinations. Manages outbound pipes, adapters, and publication matrices.

N

Nexus

Platform

Orchestrates infrastructure. Manages tenancy, event spine, and cross-domain coordination.

K

Kairos

Voice

The platform's voice. Writes the build log, synthesises insights, represents Kairo externally.

S

Sentry

Identifier

Identifies asset managers from file signatures. Detects source, format, and schema fingerprints.

O

Oracle

Explorer

Answers natural language queries about fund data. Searches across the golden record.

P

Pulse

Briefing

Generates daily platform health summaries. Tracks pipeline runs, quality scores, and delivery status.

Built for fund data teams

Replace spreadsheets, manual mappings, and email-based delivery.

AI Pipeline Builder

Upload a file and Kairo's AI maps fields to Openfunds standards automatically. Review, lock, and never map again.

Three layers of AI guardrails

Deterministic Execution

Once approved, AI steps aside. Locked pipelines run with zero hallucination risk, every time.

Why we remove AI from execution

Fund Explorer

Golden record view across all sources. Every fund with its ISINs, LEIs, NAVs, and Openfunds fields in one place.

Identifier resolution as a graph

Cross-Source Quality

Compare the same fund across providers. Spot discrepancies in NAVs, classifications, and identifiers before clients do.

Catching cross-source discrepancies

Outbound Delivery

Publication matrices, SFTP delivery, API push, and post-publish confirmation. Know your data arrived correctly.

The adapter pattern for delivery

Human-in-the-Loop Agents

Four specialist agents handle pipeline building, quality triage, delivery, and ops. They escalate only when they need you.

HITL for exceptions, not approvals

Integrations

Fits into any workflow

Kairo connects to your existing infrastructure. Ingest from anywhere, deliver to anything.

SFTP / FTP REST API Email / IMAP CSV / Excel JSON / XML PDF extraction Web scraping Client portals Data aggregators Data warehouses Custom adapters

Built for every link in the fund data chain

Wherever fund data is produced, consumed, or regulated — Kairo fits.

Primary

Asset Managers

You manufacture the data. Kairo makes sure it leaves your house clean, consistent, and on time — whether you disseminate in-house or via a service provider.

  • Automate data dissemination to platforms, aggregators, and distributors in any format
  • Populate EMT, EPT, and EET templates from a single normalised source
  • Feed RFP and DDQ responses from structured Openfunds data — not manually from PDFs
  • Ensure factsheets, KIIDs, prospectuses, and marketing all use the same values
  • Eliminate greenwashing risk from inconsistent ESG data across documents
Primary

Fund Administrators

You run 6+ systems and receive data from hundreds of sources. Kairo is the normalisation layer that cleans it before it touches anything downstream.

  • Ingest and reconcile NAV data across sources, time zones, and formats
  • Extract structured data from prospectuses and KIIDs — no more manual keying
  • Quality-check before regulatory filing to catch errors upstream
  • Unify fragmented data across legacy systems into a single golden record
  • Get data AI-ready — clean data is the prerequisite for every AI initiative
Primary

Data Service Providers

You sit between manufacturers and consumers — normalising, enriching, and routing fund data. Kairo can be your engine or help your clients send cleaner data to you.

  • Replace or augment legacy normalisation infrastructure with AI-powered mapping
  • Reduce inbound processing cost by ensuring AMs send pre-normalised data
  • Keep up with regulatory template changes (EMT v4.2, EET v1.1.3.3) without rebuilding
  • White-label opportunity: Kairo's engine behind your brand
  • Move faster than internal dev teams — operational in weeks, not quarters

Transfer Agents

Fund setup, investor onboarding, and tax reporting all depend on accurate fund terms from legal documents. Kairo extracts and structures them automatically.

  • Auto-extract fund terms, pricing rules, and cut-off times from prospectuses
  • Structure share class data for new fund launches — no more manual keying
  • Maintain accurate distribution agreements across jurisdictions
  • Feed tax reporting with clean, jurisdiction-specific fund data

WealthTech & FinTech Platforms

Data integration is the #1 reason wealthtech projects fail. Kairo gives you a clean fund data API so you can focus on your product, not plumbing.

  • API-first fund data quality layer — send raw data in, get Openfunds-normalised data back
  • Clean fund data for portfolio construction, performance reporting, and compliance
  • Accelerate M&A integration — onboard acquired platforms' data in days, not months
  • Avoid building normalisation infrastructure you'll have to maintain forever

Fund Distributors

MiFID II product governance requires clean EMT, EPT, and EET data from every manufacturer you distribute. Kairo validates it before it reaches your systems.

  • Validate inbound target market, cost, and ESG data from hundreds of manufacturers
  • Match funds to investor sustainability preferences with reliable EET data
  • Automate distributor oversight reporting back to manufacturers
  • Catch data quality issues before they affect suitability assessments

Clean Data = AI-Ready

60% of AI projects fail due to data quality. Kairo is the prerequisite.

Weeks, Not Quarters

Internal builds take 12–18 months. Kairo is operational in weeks.

Standards Evolve

EMT, EPT, EET versions keep changing. Kairo keeps up so you don't have to.

Cross-Border Ready

One fund, 15 jurisdictions, 15 regulatory requirements. One platform.

From raw file to clean delivery in three steps

Kairo handles the complexity so your team focuses on exceptions, not data wrangling.

1

Ingest your data

Drop a CSV, Excel, or JSON file. Set up SFTP or email ingestion for automated feeds. Kairo detects the schema and stores the raw data.

2

AI maps, you approve

The AI mapper suggests field mappings to Openfunds standards with confidence scores. Review, edit, and lock the pipeline. From this point, execution is deterministic.

How we make confidence scores meaningful
3

Validate and deliver

Quality rules catch issues before they leave. Outbound pipes format and route data to destinations via your publication matrix. Post-publish reconciliation confirms delivery.

Building a fund data rules engine

Security & Trust

Built like the regulated infrastructure it is

Fund data carries regulatory weight. The platform that moves it is engineered, reviewed, and hosted accordingly.

ISO 27001

Certification programme underway. Controls are mapped to Annex A across access control, encryption, secure development, supplier management, and incident response.

DORA

Built to support clients' obligations under EU 2022/2554 as an ICT third-party provider: operational resilience, incident support, register-of-information inputs, and clean exit through headless APIs.

Inherited from AWS

Hosted on AWS in London (eu-west-2) for UK data residency. The underlying infrastructure carries AWS's own ISO 27001, SOC 1/2/3, and CSA STAR attestations under the shared responsibility model.

TLS 1.2/1.3 everywhere KMS encryption at rest: database · files · cache AWS GuardDuty threat detection AWS WAF enforcing CloudTrail + Security Hub (FSBP) Secrets in AWS Secrets Manager OIDC-federated deploys · no static CI keys CycloneDX SBOM + CVE gates in CI Per-tenant isolation test harness Non-root containers A+ security headers · nonce CSP JWT with pinned algorithms · RS256-ready Human-in-the-loop release gates Append-only audit trails

External security reviews completed, all findings remediated. The full security pack is available under NDA.

From the Build Log

Notes on building a fund data platform

Architecture decisions, industry observations, and lately: a lot of UK CCI.

24 Aug 2026

CCI compliance is an evidence problem

The calculations are the easy half. The regime's real demand is recorded judgement: named approvers, reasons, and proof. Design for evidence first.

UK CCI
17 Aug 2026

CCI cost disclosure will find every gap in your data

36-month transaction windows, contractual charging terms, and the difference between zero and not applicable. Where the data pain actually lives.

UK CCI
10 Aug 2026

The CCI risk score is not the PRIIPs SRI

Ten classes, weekly pricing, floors and documented adjustments, no scenario set. Rerunning your SRI pipeline is not an option.

UK CCI
3 Aug 2026

UK CCI: what actually changes, and when

FCA 2025/52 replaces the KID and KIID with the CCI product summary. The dates, the scope, and why this is a data project before it is a documents project.

UK CCI
30 Jul 2026

Why we remove AI from the execution path

AI is brilliant at mapping fields. It's terrible at doing the same thing twice. Here's why every locked pipeline in Kairo runs deterministically.

Architecture
27 Jul 2026

The Openfunds mapping challenge

1,800+ standardised fields sounds great until every provider names them differently. How AI confidence scores solve this.

Standards
23 Jul 2026

Catching discrepancies across data sources

When two providers report different NAVs for the same fund, which one is right? Cross-source comparison is harder than it looks.

Data Quality
20 Jul 2026

Agent-first, not dashboard-first

Most platforms start with 50 screens. We started with 4. When agents handle the work, humans only need to see exceptions.

Product
16 Jul 2026

Publication matrices belong in code, not spreadsheets

Every fund data team has a delivery spreadsheet. It breaks monthly. Programmable outbound pipes replace it.

Delivery
13 Jul 2026

Five domains, not twelve services

We designed a 12-service architecture. Then threw it away. Five bounded domains give the same separation with less overhead.

Architecture
9 Jul 2026

Fund identifier resolution is a graph problem

ISINs, LEIs, SEDOLs, Bloomberg tickers — the same fund has a dozen identifiers. Why graph-based resolution beats lookup tables.

Engineering
6 Jul 2026

The SFDR data challenge nobody talks about

Sustainability regulation requires data that half the industry can't reliably produce. How we handle incomplete ESG fields.

Regulation
2 Jul 2026

Confidence scores are a trust contract

When AI maps a field at 94% confidence, what does that number actually mean? How we calibrate and display mapping certainty.

AI
29 Jun 2026

Why not just use Excel?

Most fund data teams use Excel. It works until it doesn't. The tipping point is always the same: version 47 of the master sheet.

Industry
25 Jun 2026

Why an event spine, not REST calls

Domains that talk via HTTP create coupling. Domains that emit events create flexibility. Our Redis Streams architecture.

Architecture
22 Jun 2026

Designing human-in-the-loop for exceptions, not approvals

If humans review everything, you've built a dashboard, not automation. HITL should trigger on true exceptions only.

Product
18 Jun 2026

NAV reconciliation across time zones

When Luxembourg publishes at 6pm CET and your US client expects it at 9am EST, timing becomes a data quality problem.

Data Quality
15 Jun 2026

Extracting structured data from fund documents

KIIDs, prospectuses, and factsheets contain critical data buried in PDFs. LLM extraction vs template-based approaches.

Engineering
11 Jun 2026

Multi-tenancy in fund data platforms

When two clients send data about the same fund, they both think they own it. Tenant isolation with shared golden records.

Architecture
8 Jun 2026

Building a rules engine for fund data validation

50 validation rules sounds manageable. Until you realise each one has jurisdictional exceptions. Configurable rules over hardcoded checks.

Data Quality
4 Jun 2026

The adapter pattern for downstream delivery

Every destination has its own format, auth, and semantics. Adapters isolate this complexity from the core pipeline.

Engineering
1 Jun 2026

Three layers of guardrails for AI-generated mappings

LLMs hallucinate field IDs. Here's how deterministic pre-pass, registry validation, and confidence thresholds prevent bad mappings.

AI
28 May 2026

What we learned running fund data infrastructure at scale

Seven years operating an enterprise platform taught us where automation fails and where humans can't be replaced.

Industry
25 May 2026

Why we built our own Openfunds field registry

The official spec is a PDF. We turned it into a queryable, versioned registry that the AI mapper validates against.

Standards
21 May 2026

Web scraping as a data source for fund data

When providers don't offer an API, you scrape. Legal considerations, rate limiting, and change detection.

Engineering
18 May 2026

Error handling in data pipelines at scale

Row-level errors, column-level errors, file-level errors. Three layers of granularity for meaningful triage.

Engineering
14 May 2026

The state of fund data in 2026

Regulation keeps growing, data volumes keep growing, teams stay the same size. The automation gap is widening.

Industry
12 May 2026

Deterministic vs probabilistic in regulated environments

Regulators want reproducibility. AI is probabilistic. How to get the benefits of both without the risks of either.

Regulation
11 May 2026

Why we chose Openfunds as our canonical standard

EFAMA, FinDatEx, ISO 20022, Openfunds — the fund data standards landscape. Why Openfunds won for us.

Standards
7 May 2026

Build vs buy in fund data automation

Excel, internal tools, Bloomberg Terminal, or purpose-built platform. The decision matrix most teams get wrong.

Industry
5 May 2026

Why we're building Kairo

Fund data is a solved problem that nobody has actually solved. We've spent a decade in this space and the tooling still isn't good enough.

Company
4 May 2026

Hello, world

Introducing the Kairo build log. Daily notes on building a modern fund data automation platform from scratch.

Company

See Kairo in action

We'll walk through your actual data workflow and show you how Kairo handles it.

Request a Demo

We'll be in touch within 24 hours.

Thanks! We'll be in touch.

Expect to hear from us within 24 hours.