UK CCI: what actually changes, and when

The FCA has rewritten UK retail disclosure. If you manufacture or distribute funds to UK retail investors, the documents you produce, the numbers inside them, and the records behind those numbers all change. Here is the shape of it, without the webinar padding.

The legal basis is FCA 2025/52, the Consumer Composite Investments Instrument 2025. It creates a new sourcebook, DISC, and it retires the UK versions of the PRIIPs KID and the UCITS KIID in favour of a new document: the CCI product summary. This is not a template refresh. It is a different regime with different calculations, different judgement points, and different record-keeping duties.

The dates that matter

• 2025. FCA 2025/52 is made. The DISC sourcebook exists and the clock starts.
• 5 April 2026. The legacy UK PRIIPs and KIID rules are frozen as a fixed ruleset. They still apply during transition, but they stop evolving. There is no maintenance path back; the only direction is forward.
• 1 January 2027. The first transitional provisions expire. Firms relying on transitional relief start losing it in stages.
• 8 June 2027. The full regime is in force. Every in-scope product distributed to UK retail needs CCI disclosure.

June 2027 sounds distant. It is not. Anyone who lived through PRIIPs go-live in January 2018 remembers what the final quarter looked like: every fund administrator, every data vendor, and every template provider hit capacity at the same time, and quality collapsed exactly when scrutiny peaked. The firms that had their data sorted six months early shipped calmly. The rest paid rush rates for firefighting.

What replaces the KID

The product summary keeps the consumer-facing intent of the KID but changes the machinery underneath it. The core content is prescribed; the presentation is more flexible than the KID's rigid three pages. The headline changes for fund manufacturers:

• A new risk score. A 1–10 scale computed from a 10-class annualised-volatility grid, with floors, a liquidity uplift, and room for a documented manufacturer adjustment. It is not the PRIIPs SRI wearing a new badge. We wrote a whole post on this one.
• New cost disclosure. Costs built from actual transaction history over defined windows and from contractual charging terms, presented at prescribed investment bases. Not from whatever your AuM spreadsheet implies.
• Judgement with receipts. Where the regime allows a choice, like using a representative share class or adjusting a risk score downward, that choice must be recorded, justified, and approved by a named person. The judgement is part of the disclosure.

Who is in scope

The regime covers consumer composite investments distributed to UK retail investors, and the definition is drawn wider than many firms assume. UK UCITS move onto the new documents on a determined calendar. NURS have an election path. Overseas funds in the UK market have their own routes. The honest operational answer: if UK retail investors can buy your product, assume you are in scope until you have evidence otherwise, and make that evidence a recorded fact rather than a hallway opinion. Edge cases are real, and "we assumed we were out" is not a defence the FCA has ever enjoyed hearing.

Why this is a data project first

Every requirement above lands on your data before it lands on your documents. The risk score wants ten years of weekly pricing with a freshness boundary. Cost disclosure wants 36 months of transaction history with provenance, and contractual charging terms as structured facts rather than prose in a prospectus. Scope classification wants distribution channel facts per share class. The judgement calls want an evidence trail with named approvers.

Most fund data estates cannot answer those questions today. Not because the data does not exist, but because it exists as files, emails, and tribal knowledge rather than as governed facts with sources and effective dates. The document is the last step of the pipeline. The pipeline is the project.

The firms that treat CCI as a document template exercise will discover, somewhere around March 2027, that it was a data governance exercise all along.

Over the next few weeks we will go deeper on the risk score, the cost machinery, and the evidence duties. If you want the short version for your own book: we run a readiness assessment that classifies every fund and share class against the regime and names each blocker. It is faster than a workshop and considerably more honest.