The UK CCI Regime: What Irish UCITS Managers and Boards Need to Know
- Published
- in Industry Updates
Overview of the CCI Regime
The UK Consumer Composite Investments (“CCI”) regime introduces a new disclosure framework for investment products made available to UK retail investors. The regime will apply to all UCITS marketed in the UK under the Overseas Funds Regime (“OFR”) or remaining money market funds marketed under the Temporary Marketing Permissions Regime (“TMPR”).
Under the CCI, in-scope funds will be required to produce a product summary document which distributors must provide to UK retail investors in place of the current UCITS KIID.
Manufacturers of in-scope funds must also produce a machine-readable, core information disclosure document for UK distributors.
The CCI regime reflects a broader view that KIID/KID documents are overly complex and of limited practical value to retail investors. It represents a move away from rigid, EU-style templates in favour of a more flexible, consumer-friendly approach to disclosure, while maintaining standardised information requirements to support like-for-like product comparison.
Timeline
The transitional period began on 6 April 2026. Until 8 June 2027, firms may choose whether to issue either the new product summary or continue using existing KIIDs. From 8 June 2027, the product summary is mandatory and KIIDs can no longer be used for UK retail disclosure requirements.
Some firms may prefer to adopt the product summary early, rather than refreshing their KIIDs in early 2027 only to replace them a few months later. However, a recent FCA proposal (outlined below) may remove this concern.
FCA Exemption Proposal to Waive the February 2027 KIID Review
The FCA has proposed (see CP26/24) allowing fund manufacturers to skip the annual KIID update due in February 2027, since a new product summary must be produced by June 2027. Without this waiver, fund manufacturers would bear the cost of refreshing a document that is about to become obsolete for the UK market.
If adopted, this would mean that:
- Irish-domiciled funds distributed in the UK would not need to update their KIIDs in February 2027.
- Those funds would have until 8 June 2027 to prepare and issue their new product summary.
- Distributors could continue providing existing KIIDs in the meantime, unless a material change requires an earlier update.
Where KIIDs are used outside the UK, the annual review and filing will still need to be completed for these jurisdictions. The FCA proposal affects the UK requirements only.
The Product Summary
The product summary introduced under the CCI regime is not a direct replacement of either the KIID or KID. It is a separate disclosure document that draws on the original KIID/KID model but offers greater flexibility than the prescribed format of its predecessors. The table below sets out the key differences across a number of core areas.
| Issue | KIID / PRIIPs KID | CCI Product Summary |
| Format & Length | Rigidly prescribed templates.
Maximum 2/3 pages respectively. | No prescribed template or page limit, firms have freedom to design format and layout. Conciseness expected.
|
| Language and Style | Standardised. | Consumer-friendly; jargon must be eradicated. |
| Performance | KIID: past performance; KID: forward-looking performance scenarios. | Past performance. |
| Risk | SRRI and SRI respectively. | New risk-and-return score (1-10 scale, based on standard deviation over 10-year history or a simulated/benchmark proxy). |
| Costs & Charges | Cost disclosure methodologies, depending on the product and transition status. | Standardised disclosure of ongoing, one-off and transaction costs, with machine-readable underlying data for distributors. |
| FCA Filing | To be filed with the FCA as the host Member State. | Same requirement. |
| CBI Filing | To be filed with the CBI as the home Member State for Irish funds. | Not yet confirmed. |
| Review and Updates | At least annually, with out-of-cycle updates for material changes (e.g. changes to strategy, costs or risk profile). | Same requirement. |
Next Steps for UCITS Boards
UCITS Boards should treat the product disclosure document as a material UK investor disclosure, even where their management company (“Manco”) is expected to prepare it. As a minimum, boards should consider the following actions in 2026 and early 2027:
- Implementation plan: Agree with the Manco an implementation plan, covering the proposed CCI operating model, manufacturer analysis, product summary production process, service provider inputs, distributor arrangements, regulatory filings and update triggers.
- Allocation of responsibilities: Agree how responsibility for providing input to the product summary will be divided between the fund and the Manco.
- Board approval model: Determine whether the board will approve the product summary, formally note it, or delegate approval to the Manco subject to reporting and escalation.
- Consistency check: Ensure the product summary is consistent with the prospectus, supplement(s), EU PRIIPs KID, any existing KIID during transition, factsheets, OFR disclosures, and UK platform data.
- Data controls: Ensure there are adequate controls around cost calculations, transaction cost data, underlying fund cost pull-through, risk-and-return scoring, and past performance information.
- Material contracts impact analysis: Ensure responsibility for the product summary is documented in the relevant management, investment management, administration, and/or distribution arrangements.
- Regulatory filings: Confirm whether the product summary must be filed with the FCA and/or with the CBI and which party will make the filing.
- Sample product summary: Begin preparing an initial template for validation and approval before issuing the final set of product summaries.
For further information, please reach out to your usual Maples Group contact or any of the persons listed on this page.
