For more than a decade, UK retail investment products have been accompanied by one of two disclosure documents: the UCITS Key Investor Information Document (KIID) or the PRIIPs Key Information Document (KID).
Both documents were intended to give investors standardised information that would make products easier to understand and compare. However, following extensive behavioural research, the Financial Conduct Authority (FCA) concluded that this objective had not been fully achieved. Many consumers did not engage with the documents, while those who did often found them difficult to understand or of limited practical value.
The Consumer Composite Investments (CCI) regime, introduced through the FCA’s final rules in PS25/20, is intended to address these shortcomings. It replaces the UCITS KIID and UK PRIIPs KID with a single disclosure document: the Product Summary.
For manufacturers and distributors, this is much more than a document redesign. It is the most significant change to UK retail investment disclosures since the introduction of PRIIPs. Successful implementation will require firms to review their data, calculation methodologies, governance, technology and distribution processes, not simply produce a new document.
The most significant change for manufacturers is that there is no prescribed template. Rather than replacing one standard form with another, the FCA has shifted responsibility for designing the disclosure document to firms. This makes document design, consumer testing and governance a key part of implementation, rather than simply a formatting exercise.
The FCA prescribes the information that must be disclosed and standardises the methodologies for the key metrics that enable investors to compare products. However, the design, layout, length, ordering and tone of the Product Summary are left to the manufacturer.
The standardised measures are still calculated using common methodologies across the market:
Outside these core measures, the FCA has deliberately stepped away from prescribing how firms should present information. Manufacturers are free to use colour, graphics, plain language and layered digital formats, provided the final Product Summary genuinely helps retail investors understand the product.
That flexibility comes with greater responsibility. The Product Summary sits firmly within the Consumer Duty framework, meaning firms will need to demonstrate that both the content and presentation of their disclosures support good consumer outcomes. The FCA has also made clear that it will assess readability and consumer understanding as part of its ongoing supervisory approach once the regime is live.
The CCI regime applies to consumer composite investments – a broad category covering products whose returns depend on the performance of underlying or reference assets and which are made available to UK retail investors. This includes, among other things, UCITS funds, investment trusts, structured products, structured deposits, insurance-based investment products, derivatives, contracts for difference and contingent convertible securities.
Importantly, the regime applies regardless of where the manufacturer is based. An Irish or Luxembourg UCITS marketed to UK retail investors will require a UK Product Summary in the same way as a UK-authorised fund.
This creates the defining operational challenge for cross-border managers. The EU retains the PRIIPs KID, while the UK requires the Product Summary, and the two documents are built on different methodologies for risk, performance and costs. Dual production is therefore not a copy-and-paste exercise.
6 April 2026 – The transition period began. From this date, manufacturers may voluntarily replace an existing KIID or KID with a Product Summary on a product-by-product basis.
6 April 2026 to 7 June 2027 – During the transition, firms may either continue producing their existing disclosure document or adopt the new Product Summary.
8 June 2027 – The regime becomes mandatory. Every in-scope product marketed to UK retail investors must be accompanied by a Product Summary, and KIIDs and KIDs will no longer satisfy UK disclosure requirements.
The transition period may appear generous, but there is a considerable amount of work to complete before the deadline. Firms will need to source historical pricing data, implement new calculation methodologies, design and govern a new disclosure document, build technology to support distributor data requirements, and prepare communications explaining changes such as movements in reported risk scores.
Although the implementation deadline is June 2027, firms should begin planning now. A practical starting point is to focus on three key areas:
Completing these exercises early will help identify data gaps, implementation priorities and potential operational challenges before they become critical.
For firms operating across both the UK and EU, the challenge is even greater. The transition to the Product Summary is not simply about replacing one disclosure document with another; it is about building processes capable of supporting two distinct regulatory disclosure regimes in parallel.
Firms that begin planning now will have time to validate methodologies, test Product Summaries with consumers, adapt their operating models and embed efficient production processes well before the deadline. Those that wait until 2027 risk implementing new calculations, redesigning disclosures and responding to distributor requirements simultaneously.
For many firms, this transition will be as much an operational and data transformation project as a regulatory one. Getting the scope, data, methodologies and governance right from the outset will make the move from the UCITS KIID and PRIIPs KID to the Product Summary significantly smoother.
Getting the Product Summary structure right is one thing. But once firms run their numbers through the new methodology, many may find that their risk score is higher than it was under UCITS KIID or PRIIPs. In the next article in this series, we look at why that happens and how firms can prepare for conversations with distributors. If you would like to discuss how the UK CCI regime may affect your disclosures, or would welcome support preparing your Product Summaries, please contact our Reporting team.
