FCA unveils UK-specific retail investment disclosure rules to replace PRIIPs in 2026

On 8 December 2025 the Financial Conduct Authority published final rules establishing a new retail disclosure regime for Consumer Composite Investments (CCIs), confirming that the UK will replace the Packaged Retail and Insurance-based Investment Products (PRIIPs) framework with a home‑grown regime from 6 April 2026. According to the FCA’s policy statement, the new rules are intended to address well‑documented shortcomings of the PRIIPs Key Information Document (KID) by combining a degree of standardisation with flexibility designed to produce clearer, more useful information for retail investors.

The FCA says it received 211 responses to its consultation and adjusted its drafting to reflect industry concerns while preserving core simplifications. The CCI regime is underpinned by legislation made in November 2024 and leverages the new UK Designated Activities Regime, meaning that FCA authorisation will not necessarily be required for entities carrying out CCI‑related designated activities. The rules therefore capture unauthorised manufacturers , including those based overseas , though the regulator has exempted manufacturers operating under the overseas funds regime from some governance requirements on the basis that HM Treasury considers their home jurisdictions provide equivalent protections. The FCA said certain unauthorised manufacturers will nevertheless have to comply with parts of the Principles for Businesses and meet basic UK product governance standards.

Scope and product coverage
The FCA’s final rules set out explicit inclusions and exclusions. Open‑ended fund securities, structured products and structured deposits, contracts for difference and certain insurance‑based investment products are within scope; plain vanilla corporate bonds, pension schemes and non‑structured deposits are excluded. The regulator has clarified that bonds tracking EURIBOR and similar interbank offered rates will not be treated as CCIs. Despite industry pushback, the FCA has kept securities issued by closed‑ended funds in scope, concluding that listing and Companies Act disclosures are not appropriate for retail comparability.

The FCA has also removed a previous minimum £50,000 investment test for non‑retail treatment. As a result, a product will fall outside the Product Disclosure sourcebook where marketing is clearly labelled not for retail and manufacturers adopt a distribution strategy to ensure it is not directed at retail investors.

Product summaries and machine readability
Manufacturers will produce a CCI product summary containing only information the FCA considers mandatory, with freedom to add supplementary material to aid consumer understanding. The FCA retained its requirement that manufacturers make underlying information available to distributors in a machine‑readable file, although it relaxed that obligation where the manufacturer is also the only distributor.

Costs and charges
The FCA moved away from its original proposal for a single aggregated cost figure after respondents objected to aggregating one‑off and transaction costs with ongoing costs. The final rules require an ongoing costs headline figure presented both as a percentage and as a pounds‑and‑pence amount, with one‑off costs and explicit transaction costs disclosed separately. The regulator treats mark‑ups and mark‑downs as explicit costs that must be included, while considering bid‑ask spreads to be implicit transaction costs that do not have to be listed. If a cost category is zero it need not appear in the product summary, but manufacturers must confirm zero‑cost categories in the underlying information file. The FCA retains an obligation to “pull through” underlying costs into the ongoing costs figure for most products, but will not require costs of underlying closed‑ended funds to be added to that headline figure, provided those costs are clearly presented.

Risk and return
The regulator has revised its proposed risk‑and‑return metric following consultation. Instead of a five‑year standard deviation, the score will be calculated on the standard deviation of returns over 10 years to better capture long‑term volatility; products with under 10 years’ history must use simulated past performance. The FCA has clarified the label to make clear it is a risk‑and‑return score. It also abandoned a proposal to assign an automatic top risk score to certain low‑liquidity products; instead manufacturers must increase a product’s risk‑and‑return score by at least one notch if the product invests in illiquid assets or imposes delay or added cost on redemption. Structured products , which lack past returns data , will use a value‑at‑risk equivalent volatility model to generate their score.

Distributors and liability concerns
The FCA has removed an earlier proposal that would have allowed distributors to create or amend product summaries. Citing concerns that edits by distributors would create liability risks and impose additional compliance burdens on manufacturers, the final rules require distributors to deliver manufacturers’ unamended product summaries to consumers in a durable medium at or shortly after point of sale. Distributors must still draw consumers’ attention to certain minimum pre‑sale information but otherwise have latitude over how to highlight relevant material in the customer journey. The FCA also relaxed rules it had proposed on “downplaying” elements of the product summary to give distributors greater flexibility.

Timing and transition
Legislation will repeal the UK PRIIPs Regulation and bring the CCI framework into force on 6 April 2026. The FCA confirmed an optional transitional window: from 6 April 2026 until 7 June 2027 manufacturers may choose to use either the new CCI product summary or the existing PRIIPs KID. From 8 June 2027 it will be mandatory to use the CCI format. The FCA acknowledged respondents’ warnings that running two disclosure formats in parallel could confuse consumers and complicate distributors’ operations, but defended the optional transition as a means of allowing firms to move away from the PRIIPs KID as soon as they are ready.

Market reaction and broader context
Advisers and industry commentators have broadly welcomed the move to a UK‑tailored regime while warning that significant implementation work remains. PwC commented that the new framework replaces both PRIIPs and certain UCITS disclosure requirements and praised the FCA’s focus on clearer, more engaging information, while noting the operational challenge for firms migrating systems and workflows ahead of the mandatory deadline. Legal advisers who responded during consultation pressed for clarity on scope and distributor obligations; industry bodies had argued for more prescriptive standardisation but the FCA has preferred a lighter touch to encourage innovation in how product information is presented.

Next steps
Firms manufacturing and distributing CCI‑in‑scope products must prepare for the new machine‑readable information requirements, recalculation of costs and risk metrics, and distribution‑process changes that will be tested during the optional transition. The FCA has indicated it will undertake a wider review of the MiFID costs and charges disclosure regime in 2026 to consider alignment issues the CCI rules do not resolve now.

According to the original report, the new regime is designed to strike a balance between comparability and innovation; how quickly manufacturers move from PRIIPs KIDs to CCI product summaries , and whether consumers find the new disclosures clearer and more useful in practice , will be the clearest indicators of the regime’s success.