FCA publishes final CCI rules

On 8 December 2025, the FCA published final rules on the new Consumer Composite Investments (CCI) regime, which will replace the current UK's Packaged Retail and Insurance-based Investment Products (PRIIPs) regime.

The FCA consulted on the new CCI regime in December 2024 and April 2025. To reflect market feedback, in the final rules the FCA has made the following changes:

• expressly excluded from the regime plain vanilla listed bonds (to be defined through future changes to the FCA Handbook) and bonds linked to interbank offered rates;
• simplified the "non-retail" exclusion by removing the proposed £50,000 minimum investment amount;
• assigned sole responsibility for the product summary to manufacturers, so that distributors must use manufacturers' product summaries without amendments; 
• clarified that manufacturers that are the only distributors of their products need not provide underlying product information in a machine-readable format;
• re-labelled the risk score as a "risk and return" score that acknowledges potential returns as well as risk;
• clarified that explicit transaction costs and one-off costs need not be included in the headline ongoing costs figure;
• required structured products costs to be disclosed where they are known and, for products with maturity of under a year, over the life of the product;
• specified a tailored value-at-risk equivalent volatility methodology for calculating structured products' risk and return scores;
• removed the requirement for illiquid products to automatically have a score of 9; and
• added a requirement for products that invest in illiquid assets or feature investor access delays to have their scores increased by at least 1.

The FCA's final rules supplement the Consumer Composite Investments (Designated Activities) Regulations 2024, which were made in November 2024.

Most of the new CCI rules will apply from 6 April 2026. However, importantly for those needing to implement new procedures, firms that are not ready to produce CCI product summaries by then can continue to provide PRIIPs KIDs until 8 June 2027.

We discuss the key changes to the original draft CCI rules below.

Scope of CCI regime

The main changes made to the FCA's proposed scope are that:

• plain vanilla listed bonds (to be defined through future changes to the FCA Handbook)

• bonds linked to interbank offered rates are also excluded; and

• the proposed "non-retail" £50,000 minimum investment amount has been removed. Accordingly, products are now out of scope if they are clearly marked as not for retail and not directed to retail investors.

Manufacturer and distributor interaction

Under the new regime, manufacturers need to provide a product summary and related underlying core information to the distributor "in good time" before product distribution. 

The FCA had originally proposed that distributors should be able to amend the manufacturer's product summary or create their own, but in response to market concerns around liability this has been reversed so that distributors must use the manufacturer's product summary.

The key requirement on distributors is to highlight the information that investors need to make an informed decision, including:

• a brief explanation of the product;
• the ongoing costs figure and other relevant costs (also see Costs information below); and
• the product's risk and return score, with an explanation of the risk and return profile and any prescribed warnings.

The FCA has also explicitly stated that distributors must not direct or sell to a retail client any CCI product that does not have an up-to-date product summary, to remove any ambiguity.

Manufacturers still need to provide distributors with underlying core product information in a machine-readable format, but the FCA has introduced a carve-out from the machine-readable format where the manufacturer is the only distributor.

Costs information

There is an overriding requirement that the costs associated with a product are described in a way that is clear, fair and not misleading. This applies to all costs that impact the consumer's investment, whether direct or indirect.

Ongoing costs need to be presented as an aggregated "headline" figure. Explicit transaction costs and one-off costs should not be included in the headline figure but do need to be disclosed prominently elsewhere.

For structured products with a maturity date of under a year, costs should be shown over the lifetime of the product.

Risk and return

The risk score has been re-designated a "risk and return" score, and now needs to give a balanced view of both the risks of and the possible return on a product.

The 1-10 linear scale remains, but the FCA has changed the calculation of the standard deviation of returns to over 10 years rather than over 5 years. Products with less than 10 years of returns must use simulated past performance using the history of the underlying assets or an appropriate benchmark where that is not possible.

Structured products and derivatives

Structured products and derivatives are specifically referenced throughout the final rules, recognising that they are inherently different from many of the other products covered by the regime.

The FCA has removed the requirement for structured products and derivatives to automatically be assigned a minimum risk and return score of 9, but any product that invests in illiquid assets or features an access delay or cost needs to have its score increased by at least 1 (unless it is already scored 9 or is regularly traded on an exchange). 

Structured products are assigned a specific calculation methodology based on value-at-risk equivalent volatility, to recognise that their non linear pay offs and bespoke features cannot be effectively represented by underlying-asset volatility alone.

Capital-at-risk structured products with returns tied to the performance of multiple indices or featuring gearing need to include an additional warning flagging the increased complexity and the risk of consumer misunderstanding.

Interaction with Consumer Duty

The CCI regime overlaps in places with the FCA's Consumer Duty. To ensure consistency, the FCA has amended the requirement for distributors to report product summary errors to other firms in the distribution chain so that it aligns more closely with corresponding language in the Consumer Duty. 

In the first half of 2026, the FCA intends to consult on changes to the application and requirements of the Consumer Duty, including in relation to firms working together in distribution chains and the sharing of information throughout the chain. Any changes will also apply to the CCI rules, ensuring consistency across the FCA Handbook and providing clarity on firms' obligations.

Commentary

The FCA's changes to the final rules, and in particular the flexible transitional provisions, will be welcomed by the market. 

Nevertheless, for international firms that need to follow two separate regimes and produce different disclosure documents for UK CCIs and EU PRIIPs, a substantial new build will be required to cater for the new regime, and the impact on these firms will only increase as the UK and EU disclosure regimes continue to diverge.