Wealth Management
The FCA’s CCI regime represents one of the most significant changes to UK retail investment disclosure since the introduction of EU Packaged Retail and Insurance-based Investment Products (PRIIPs) Key Information Document (KID) and Undertakings for Collective Investment in Transferrable Securities (UCITS) Key Investor Information Document (KIID). With PS25/20 setting out the FCA’s final rules in December 2025, the direction of travel is clear: the UK is moving away from prescribed, template-led disclosure and toward a more flexible, consumer-focused product information framework. The regime began its optional transition on April 6, 2026 and comes fully into force on June 8, 2027, giving firms a limited window to redesign not only documents, but the operating model that supports them.
CCI is not simply a document replacement. It marks a shift from prescribed disclosure to accountable communication, where firms must evidence that product information supports better investor decisions.
CCI should not be viewed as a narrow disclosure replacement exercise. It sits within a broader shift in UK regulation from prescriptive rule-setting to outcome-driven oversight, where firms are expected to demonstrate accountability, effective controls, and good consumer outcomes in practice. The FCA’s wider consumer investments agenda is also aimed at supporting a stronger retail investment culture in the UK, with around 19 million UK adults holding retail investment products.1
The replacement of the PRIIPs KID and UCITS KIID with the Product Summary Document (PSD) changes the nature of disclosure. Firms are no longer simply completing a standard template. They are designing a consumer-facing communication that must stand on its own, be separate from marketing material, and give retail investors a reasonable and sufficient understanding of the product’s nature, objectives, risks and costs. The PSD must also be maintained, reviewed at least annually, and updated where required to ensure the information remains current and compliant.
Several technical changes will drive operational complexity:
Risk and return: Information moves to a 1 to 10 scale, with the risk and return score presented clearly and prominently in the product summary. The FCA has also changed the volatility calculation period to 10 years, with simulated past performance required where a product has less than 10 years of history, unless this cannot reasonably be done. Past performance is expected to be shown through a line graph, with at least one data point for the last day of each month during the relevant period and, for sterling products, a £10,000 illustrative investment amount.
Customer journey: Under PRIIPs and UCITS KIID, disclosure was often treated as a document fulfillment process: produce, host, distribute, and evidence delivery. Under CCI, disclosure becomes part of the decision journey. Product information must be available when it matters, in a form that supports understanding, comparison, and action. For platforms, advisers and distributors, this raises questions about digital placement, sequencing, prominence, accessibility, version control, and consistency across advised, non-advised, and execution-only journeys.
Targeted support alignment: The FCA has now confirmed final rules for targeted support in PS25/22, allowing firms to offer suggestions to groups of customers with common characteristics. The regime is designed to help consumers make effective, timely, and informed decisions about pensions and retail investments, while retaining the protection that comes from engagement with an authorised firm. In that context, CCI product information will become part of the infrastructure that supports guided decision-making. If firms are able to suggest courses of action to cohorts of consumers, the clarity and usability of product information become even more consequential.
Distributed accountability: Manufacturers are responsible for producing core product information and product summaries, while distributors are responsible for offering, advising on or selling CCIs, or providing investment services relating to CCIs to retail investors. Manufacturers will, therefore, need to ensure downstream partners can access the right data, understand the methodology, and present the information consistently within their own journeys. This will require more than publication of a PDF. It will require clear data standards, robust distribution mechanisms, controlled updates, evidence of delivery, and feedback loops from distributors.
The PSD will only succeed if it works in the customer journey. Firms need to think beyond production and consider how information is presented, understood, and acted on across platforms, advisers, and distributors.
For firms, the risk is underestimating the breadth of change as CCI affects product governance, data sourcing, methodology interpretation, rules engines, financial promotions, digital experience, adviser processes, platform integration, and oversight. Firms operating cross-border will also need to manage divergence between the UK CCI regime and EU PRIIPs requirements, increasing the need for clear product scoping and dual-regime governance.
The supervisory focus is likely to fall on defensibility. Firms should expect challenge on how methodologies were defined, how assumptions were approved, how data gaps were managed, how PSDs were tested for consumer understanding, and how disclosure integrity is maintained across distribution channels. In practice, this means firms need audit trails, governance forums, model validation, data lineage, clear RACI, and ongoing monitoring of outcomes.
The firms that act early will be better positioned to turn CCI into more than a regulatory response. A well-designed PSD can improve transparency, reduce customer confusion, support better conversations with advisers and distributors, and strengthen trust in retail investment markets. Poor implementation, by contrast, risks inconsistent disclosures, weak customer understanding, downstream misinterpretation, and regulatory remediation.
How can Capco help?
Capco supports firms across the full CCI lifecycle, from regulatory interpretation through to implementation and post-go-live assurance. We help clients assess product scope, interpret methodology requirements, identify gaps in existing PRIIPs and UCITS KIID processes, and define practical roadmaps and process changes to meet the June 2027 deadline.
Our teams support Product Summary Document (PSD) design, customer journey integration, data sourcing, rules engine requirements, governance frameworks, operating model design, and distributor engagement. We also help firms move from assessment to delivery, including build versus buy analysis, vendor selection, testing, parallel run, financial promotion controls, and rollout planning.
With AI-enabled accelerators, Capco can support regulatory mapping, document review, data quality assessment, control testing, and management information. The outcome is not simply compliance with CCI, but a scalable disclosure capability that reduces delivery risk, strengthens accountability and supports better retail investor outcomes.
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