Key points from the FCA’s draft CCI rules – a Simmons client note

Update: On 16 April 2025 the FCA released a second Consultation Paper on the Consumer Composite Investments regime, see our article here: FCA consults on further proposals for Consumer Composite Investments | Simmons & Simmons

As we reported at the time, on 19 December 2024, the FCA published a consultation paper, "A new product information framework for Consumer Composite Investments" (the CP).

The CP sets out  draft product information rules that will underpin the new Consumer Composite Investments (CCI) regime.

Our client note examines the key issues arising from the FCA's draft rules.

What is the CCI Framework?

Following Brexit, HMT committed to replacing the UK's disclosure regimes for PRIIPs and UCITS with a domestic CCI framework.  

The aim is to change how product information must be presented. There will be a move away from the rigidly templated PRIIPs KIDs and UCITS KIIDs towards a more flexible and simpler approach that puts the emphasis on empowering consumers to make effective, timely, and properly informed decisions.

The relevant legislation was enacted in November 2024 - products that had previously fallen under the disclosure regimes for PRIIPs and UCITS (including overseas funds in the Overseas Funds Regime) now fall under the CCI framework.

The consultation closes on 20 March 2025 and a policy statement containing the final rules is expected later in 2025.

Who is this relevant to?

The draft rules will be of interest to - among others - firms which manufacture, advise on or sell

• PRIIPs

• UCITS (both UK and overseas funds)

• NURS or

• non-PRIIP packaged products (other than pensions products).

What is a CCI?

Under the FCA's proposals, a CCI is "an investment where the returns depend on the performance of, or changes in, the value of indirect investments" - the following products will be included:

• structured deposits

• securities which embed a derivative or include features equivalent to a derivative contract

• debt securities with certain features

• securities issued by a fund, or rights to or interests in such a security

• securities issued by a closed-ended investment fund

• contingent convertible securities

• contracts for difference

• insurance-based investment products.

UK-listed closed ended investment funds will also be included in the CCI regime, despite their recent exclusion from the UK PRIIPs regime.