The UK’s Consumer Composite Investments regime: What overseas managers need to know

For overseas fund managers, the UK’s new Consumer Composite Investments (CCI) regime is more than a domestic replacement for the UK PRIIPs KID or UK UCITS KIID. It will drastically change the fund-level information that such managers need to produce for UK retail channels. 

This matters for any non-UK manager whose funds are, or may be, distributed to UK retail investors. The new regime replaces the UK PRIIPs KID and UK UCITS KIID disclosure regimes and is designed to give firms greater flexibility over how they communicate with consumers, while still requiring key information on costs, risks, returns and past performance to be presented on a consistent basis.

The full CCI regime comes into force on 8 June 2027 and will require all firms in scope to undertake significant planning and modification of operational processes. The transition period is already underway. 

There is a lot to think about in a short timeframe, but for our overseas manager clients, we are highlighting the following key points.

1. Being overseas is not a safe harbour

The key question is not where the manager is based, but whether a product is distributed to a retail investor in the UK. The CCI regime applies to firms that manufacture such products, or distribute such products, and, crucially for overseas managers, the FCA’s rules do apply to certain activities undertaken by firms who are not themselves FCA-authorised, including overseas firms.

The FCA has expressly identified overseas fund managers as being within the population affected by the regime. 

The first practical step is therefore a scope-mapping exercise: which products reach UK retail investors, through which channels and which entities are responsible under the new rules either as a manufacturer or a distributor?

2. UCITS and OFR funds are in scope

The new regime applies to products currently subject to the PRIIPs regime as well as UCITS funds where they are made available to UK retail investors. 

This includes eligible EEA UCITS marketed to UK retail investors through the Overseas Funds Regime (OFR). 

For European managers, this means that they will be required to produce a “CCI product summary” for such funds. Overseas managers will likely position adoption within the same implementation workstream as the OFR and other UK market-access arrangements, rather than being treated as a separate disclosure issue.

3. Work out who is the “manufacturer”

This matters because responsibility for producing the CCI product summary generally sits with the manufacturer.

The FCA’s definition of “manufacturer” is deliberately broad and covers a person who creates, develops, designs, issues, manages or operates a CCI. 

Overseas managers should therefore establish who is treated as the “manufacturer” for each relevant product, particularly where there are multiple entities within a group or where fund management and distribution responsibilities are split. That allocation should be recorded clearly in internal governance documents and, where relevant, in distribution or service arrangements.

4. Distributor arrangements need early planning

The new CCI product summary is not simply a manufacturer disclosure exercise.

UK distributors will need to understand the products they distribute and fulfil their own obligations when communicating with retail investors. The FCA’s framework gives distributors flexibility over how product information is presented and allows them to tailor communications to the needs of their retail customers. 

Overseas managers should therefore engage with their UK distributors early to agree who is responsible for what, what information will be provided, how information will flow between manufacturer and distributor and how changes will be escalated. This is a contractual and operational issue, not only a regulatory disclosure issue.

5. The CCI product summary is not a re-badged KID or KIID

The CCI regime replaces the existing UK PRIIPs KID and UK UCITS KIID requirements with a new CCI product summary which will look and feel very different to its European predecessors.

The UK’s new framework is deliberately more flexible. The FCA prescribes the information it considers necessary for consumers to make informed decisions but gives manufacturers considerably more freedom over the design and presentation of that information.

This should be viewed as an opportunity to rethink how products are explained to UK retail investors, rather than simply as another mandatory disclosure document. 

6. Do not assume EU disclosures can simply be copied across

For overseas managers already producing European fund documentation, there may be an understandable temptation to treat the CCI product summary as the UK version of an existing disclosure exercise. 

That could miss the point. The FCA wants the new regime to support consumer understanding and has deliberately moved away from the highly prescriptive approach associated with PRIIPs and UCITS disclosures. Its recent review found significant shortcomings in the readability and intelligibility of existing pre-sale investment disclosures. This is an area of focus for the UK regulator. 

Overseas managers should therefore ask whether their proposed UK disclosure genuinely explains the product to the intended investor, rather than simply whether it contains all required information. The concept will be familiar to UK authorised firms who have recently navigated the adoption of the UK’s Consumer Duty. Overseas managers may be less familiar with this style of disclosure.

7. Keep the data behind costs, risk and returns defensible

Greater flexibility does not mean that firms can choose which information to provide. 

The FCA has retained standardised requirements around key information, including costs, risk and return and past performance, so that consumers can compare products on a consistent basis. Crucially, these prescribed methodologies are different to those previously mandated for the UK PRIIPs KID and UK UCITS KIID.

For overseas managers, this means ensuring that the underlying data, calculations and methodologies supporting the CCI product summary are robust, documented and capable of being provided to UK distributors where necessary.

8. Be aware of the UK’s financial promotions regime

Unlike many European jurisdictions, the UK has a separate financial promotions regime, which prohibits unauthorised firms from disseminating financial promotions unless such promotions are approved by a UK authorised person, or an exemption applies. 

Previously, mandatory fund disclosures for retail clients (for example the UCITS KIID) were explicitly carved out of the UK’s financial promotions regime. However, this is not the case for the new CCI product summary: the CCI product summary will be deemed a “financial promotion” under UK rules.

Overseas managers who produce CCI product summaries will therefore have to ensure that these are approved by a UK authorised person. This may be easier for larger managers who have a UK authorised entity within their group – but may be challenging for overseas managers without a UK presence, who may have to rely upon an appropriately authorised firm providing this service on a paid-for basis.

9. Start implementation conversations now

The transition period provides an opportunity for manufacturers and distributors to resolve operational issues before the June 2027 deadline.

That discussion should include agreeing:

• Who will produce the CCI product summary;
• How the CCI product summary will comply with the UK’s financial promotions regime;
• What underlying information the distributor requires;
• When and how updates will be communicated;
• Who is responsible for maintaining the information;
• How the correct version will be made available to UK retail investors;
• What events will trigger review, withdrawal or replacement of the information; and
• What evidence will be kept to show that the product information remains accurate and understandable.

The FCA has specifically emphasised the need for manufacturers and distributors to work together during implementation and to manage the associated operational risks.

10. Treat CCI as a consumer-understanding exercise, not a paper exercise

Perhaps the most important point for overseas managers is that CCI product summaries should not be approached as a technical replacement for the PRIIPs KID or UCITS KIID.

The FCA’s stated objective is to give consumers concise, clear information at the right time so that they can make effective and properly informed investment decisions. This makes the adoption of CCI product summaries an important part of the wider UK regulatory focus on consumer-centric communications.

For overseas managers, the practical question is therefore not simply: “Have we produced a compliant CCI product summary?” It is: “Does the information we provide help a UK retail investor understand what they are investing in, including the costs, risks and potential returns?”

What should overseas managers do now?

With the implementation deadline approaching, overseas managers should be starting to:

1. Map their UK retail distribution arrangements and identify products within scope;
2. Confirm the relevant manufacturer and distributor responsibilities;
3. Assess the impact on existing UK fund documentation, governance and operational processes;
4. Engage with UK distributors about information requirements and customer journeys;
5. Test whether existing product information genuinely supports consumer understanding;
6. Agree approval, update and version-control processes with UK distributors; and
7. Identify any products, investor types or distribution routes that should be excluded from the CCI implementation workstream.

For overseas managers with established UK distribution, early engagement with distributors and advisers should help identify any gaps before the new regime becomes fully effective. 

If you have any questions or would like to discuss how the UK’s new Consumer Composite Investment regime will affect your firm, please contact Jessica Reed, Sarah Logeswaran or any other member of our Funds and Financial Regulation team.

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Written by Jessica Reed and Sarah Logeswaran