The FCA's new disclosure regime for retail investment products — replacing PRIIPs KIDs and UCITS KIIDs with a product summary built around consumer understanding.
A Consumer Composite Investment (CCI) is an investment where the returns a retail investor receives depend on the performance of, or changes in the value of, indirect investments. In practice this covers most packaged retail products previously in scope of the UK PRIIPs regime — funds (including UCITS and investment trusts), structured products, insurance-based investments and derivatives — when they are made available to retail investors in the UK.
The regime was consulted on in CP24/30, finalised in Policy Statement PS25/20 on 8 December 2025, and commenced on 6 April 2026. It replaces the EU-inherited PRIIPs and UCITS disclosure frameworks with a single UK regime.
The prescriptive Key Information Document is replaced by a more flexible product summary. But the bigger shift is regulatory philosophy: the CCI rules work alongside the Consumer Duty, so producing a compliant document is no longer enough. Firms must be able to show that their disclosures support the consumer understanding outcome — that real customers in the target market can find, comprehend and act on the information.
That makes testing of communications — and evidence from that testing — the hard part of CCI compliance. This is exactly what Miggins does: persona-based consumer testing of product summaries and client communications, with audit-ready evidence of comprehension. See Consumer Duty testing for how it works.
A Consumer Composite Investment is an investment where the returns depend on the performance of, or changes in the value of, indirect investments — broadly the products previously in scope of the UK PRIIPs regime, such as funds, structured products, insurance-based investments and derivatives, when made available to retail investors in the UK.
The FCA published its final rules in Policy Statement PS25/20 on 8 December 2025 and the CCI framework commenced on 6 April 2026. Firms have a transition period until 8 June 2027, after which the UK PRIIPs KID and UCITS KIID can no longer be used and the CCI product summary is mandatory.
The prescriptive PRIIPs Key Information Document and UCITS Key Investor Information Document are replaced by a more flexible CCI product summary, supported by ongoing Consumer Duty obligations to ensure retail investors actually understand the information they receive.
The CCI regime is outcomes-based: rather than only completing a template, firms must be able to evidence that their product summaries and supporting communications support consumer understanding under the Consumer Duty. Testing communications with target-market consumers, and acting on the results, is central to that evidence.
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