Briefing For UCITS And AIFMs Marketing To Retail Investors In The UK

The Consumer Composite Investments Regime

The new UK Consumer Composite Investments (CCI) regime will apply to all UCITS marketed in the UK under the Overseas Fund Regime (OFR) from 8 June 2027. The regime will also apply to AIFMs marketing to retail investors in the UK.

Under the CCI, in-scope funds will be required to produce a new product summary document which must be provided by distributors to UK retail investors. 

Manufacturers of in-scope funds will also need to provide a second machine-readable document to UK distributors referred to as the “core information disclosures”.

The Product Summary

The product summary will replace the UCITS KIID currently provided to UK retail investors.

It is a manufacturer-produced document which must contain certain prescribed information including product characteristics, risk and return, costs and charges and past performance, as well as additional information determined by the manufacturer(s).

In contrast to the UCITS KIID, manufacturers have greater freedom to design the product summary with prescribed document length and formatting requirements being removed. The aim is to make the product summary more consumer friendly and engaging. 

The product summary must include the following:

• a brief description of the investment objective and investment policy;

• information about risk and return including a 1-10 risk score based on the FCA’s prescribed volatility calculation method and ranking grid;

• information about past performance;

• information about costs and charges;

• product information such as name/identifier, manufacturer and date; and

• information on complaints and compensation schemes.

The product summary must be filed with the FCA.

Core Information Disclosures

Manufacturers must also provide distributors with a separate machine-readable document to enable easy comparison between products.

The CCI regime imposes specific obligations on both manufacturers and distributors as well as requiring them to collaborate and engage with each other. 

Both the product summary and core information document must be reviewed and updated at least once a year and must be available on a publicly accessible website.

FCA Rules

The final FCA rules and guidance are available here.

Impact Assessment for UCITS in the OFR

• Firms should discuss the CCI regime with their management company, current UCITS KIID producer and UK distributors to assess the impact of the new regime for their products marketed to retail investors in the UK. Given the level of work that will be involved in complying with the CCI, early engagement with relevant stakeholders is recommended.

• Firms will need to assess which entity is acting as the manufacturer under the CCI regime and therefore responsible for producing and updating the product summary and core information disclosures.

• Where more than one party is responsible for manufacturing a product summary and core information disclosures, the FCA expects that the division of responsibility is agreed in writing.

• Agreements with UK distributors will need to be reviewed to cover the additional responsibilities being introduced under the CCI.

• As the product summary will be considered a “financial promotion”. under UK rules, firms should consider who will take responsibility for its approval.

• It is still unclear whether the product summary will need to be filed with the UCITS home regulator.

• The CCI regime will run in parallel with the existing UCITS regime until its full implementation on 8 June 2027. UCITS will need to decide whether they will adopt the new regime prior to the UCITS KIID annual update in February 2027.