Legal development

Consumer Composite Investments replace UK PRIIPs

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    As of 6 April 2026, the new UK Consumer Composite Investments (CCI) regime has replaced the old PRIIPs framework.

    The CCI regime consists primarily of the Consumer Composite Investments (Designated Activities) Regulations 2024 and the FCA's new Product Disclosure sourcebook (DISC), which together establish rules for the manufacture and distribution of consumer composite investments (CCIs). 

    The FCA previously consulted on the new CCI regime in December 2024 and April 2025, and published its final rules in December 2025.

    CCIs are broadly comparable in scope to the packaged retail and insurance-based investment products (PRIIPs) governed by the repealed framework, but there are some important differences between the two regimes.

    Key points to note under the CCI regime are:

    • the previous PRIIPs KID document has been replaced with a CCI "product summary", allowing for more bespoke disclosure (with no page limit) so that manufacturers can present information in the most investor-friendly way;
    • the CCI risk scale runs from 1-10 (replacing 1-7) and must present a balanced view of the risks and potential returns of a product. Products investing in illiquid assets or with an access delay/cost must have their score increased by at least 1, unless they are already scored 9 or regularly traded on an exchange;
    • manufacturers bear full responsibility for the accuracy and adequacy of product summaries; 
    • distributors must use product summaries without amendment, and may not sell or direct to a retail client any CCI product that does not have an up-to-date product summary;
    • "plain vanilla listed bonds" (now defined in the FCA Handbook) and bonds linked to interbank offered rates are expressly excluded from the regime;
    • the proposed "non-retail" £50,000 minimum investment threshold has been removed, so products fall out of scope if clearly marked as not for retail and not directed at retail investors, irrespective of the minimum investment;
    • structured product manufacturers can use a tailored value-at-risk equivalent volatility methodology to calculate risk and return scores.

    Whilst the new CCI regime took effect on 6 April, firms may continue to produce PRIIPs KIDs instead of product summaries until the grandfathering deadline of 8 June 2027.

    The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to.
    Readers should take legal advice before applying it to specific issues or transactions.