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CCI product summary checklist: what the FCA's DISC rules require

From 8 June 2027, funds and other consumer composite investments (CCIs) sold to UK retail investors need a product summary under the FCA's new DISC rules. There is no FCA template, so firms must design their own. This checklist sets out what each summary must contain, section by section, with the rule references.

Last reviewed 8 October 2026 · About 8 minutes to read

Please note: this checklist summarises the rules as we understand them at the date of review. It is general information, not legal or regulatory advice. Always check the current rules in the FCA Handbook and take professional advice before relying on it. See our Terms and Disclaimer.

1. Before you start

• Is the product a CCI? UK funds and recognised overseas funds sold to UK retail investors, including Irish and Luxembourg UCITS ETFs under the Overseas Funds Regime, are in scope, along with other packaged products.
• Know your dates. The rules took effect on 6 April 2026. Existing UCITS KIIDs and PRIIPs KIDs can be used until 7 June 2027, and product summaries are mandatory from 8 June 2027. Some distributors may ask for them earlier, possibly from around mid-February 2027.
• Plan for approval. A product summary does not benefit from the old KID exemption from the financial promotion rules, so it needs approving as a retail financial promotion by a firm with permission to do so.
• Leave time for testing. The regime sits under the Consumer Duty, so firms should be able to show the summary actually helps investors understand the product.

2. Format and presentation

• Titled "product summary"
• Short, concise and written in plain English that retail investors can understand
• Clearly separate from other marketing materials (DISC 3.1.1R)
• Your own layout: the FCA sets the content and calculations, not the design, apart from the risk scale and the performance graph
• One summary for each share class, with its own figures

3. Product information (DISC 4)

• Product name, share class and identifier such as the ISIN
• Manufacturer's name and the product's authorisation status, including for overseas funds that they are not authorised in the UK
• What the product is and its objective and strategy, in plain words
• What drives returns, and that investors could lose some or all of their money
• The recommended holding period, with the warning that the product may not be appropriate for investors who plan to withdraw their money within that period
• How to sell or get money out, and any charges or notice periods
• How to complain, and the position on the Financial Ombudsman Service and compensation. For overseas funds, use the COBS 4.15 statements that UK protections are unlikely to apply
• Where to find the prospectus, reports and prices

4. Risk and return (DISC 5)

The new score runs from 1 to 10 and replaces the 1 to 7 indicators in the KIID and KID.

• Score calculated from annualised volatility over 10 years, using weekly prices where available. Missing years must be simulated, using a benchmark only if simulation is not possible (DISC 5.2)
• Volatility mapped to the score using the FCA's bands, from under 0.5% for a 1 to 50% and over for a 10 (DISC 5.4)
• Minimum scores applied where required, for example at least 9 for products with less than 5 years of volatility record, CFDs, contingent convertibles, VCTs and EIS investments (DISC 5.5)
• 1 added for products that cannot readily be sold, and a score of 10 where investors could lose more than they invest (DISC 5.6)
• Score checked to make sure it fairly reflects the product's risks, and adjusted if not
• Score shown on a horizontal 1 to 10 scale (DISC 5.7)
• Narrative explaining what the score means, that higher potential returns come with a greater risk of loss, how the product behaves in severely adverse markets, and its other material risks such as currency, concentration or liquidity (DISC 5.8)
• Warning that the risk may be significantly higher if the product is not held for the recommended holding period
• Score calculation kept for at least 5 years

5. Costs (DISC 6)

• Costs shown as a percentage and in pounds, based on an assumed investment of £10,000, or £1,000 a year for regular-premium products
• Ongoing costs as one headline figure
• Transaction costs shown separately, based on an average over recent years
• Entry and exit costs, and any performance fee or carried interest, with an explanation of how a performance fee works
• Why costs matter: they reduce what the investor gets back
• That the seller, platform or adviser may charge more on top
• Which figures, if any, are estimates

6. Past performance (DISC 7)

• A line graph of what £10,000 would have been worth over up to 10 years, using monthly values, after costs
• Graph ending no earlier than 60 days before the summary is prepared
• A prominent warning that past performance is not a guide to future performance
• The year the product was launched, the period shown, the currency and the source of the data
• A benchmark where the product has one, or an explanation where it does not (DISC 7.3)
• For listed funds, share price as well as net asset value where the two differ
• A clear note where the product has less than 10 years of history

7. Data for distributors and keeping it up to date

• Machine-readable data. Manufacturers must give distributors the underlying product information (general, risk, cost and performance data) in a machine-readable form such as CSV. This is not needed if the manufacturer is the only distributor. There is no FCA format: FinDatEx is updating its EMT and EPT templates for CCI, expected in early 2027.
• Review. At least every 12 months, and after a material change to the product or market events that materially alter the risk and return information (DISC 3.2).
• Records. Keep each version for at least 3 years.
• Factsheets. When a fund switches, update its UK factsheet to show the 1 to 10 score and figures that match the product summary.

8. Common mistakes to avoid

These came up when we tested our own example CCI product summary against the rules.

• Promotional words. "Low-cost", "high-quality" or "best-in-class" in a regulated summary invite challenge unless you can prove them. Describe, don't sell.
• Figures that don't agree. A worst fall from peak, a worst calendar year and a worst 12 months are different numbers. Label each one, and calculate every figure from the same data.
• Describing a method you didn't use. If the score is not yet based on 10 years of weekly prices with simulated history, don't say it is.
• Dropping required warnings in a redesign. The holding-period warning and the "what drives returns" explanation are easy to lose when making a summary more engaging.
• Extras that look like advice. A "Is this right for me?" box can read as a suitability verdict. Present target market information as general information, not advice.
• Wrong protection wording for overseas funds. Irish and Luxembourg funds need the COBS 4.15 wording on the Ombudsman and FSCS, not the wording for UK funds.

See both versions of our example, Essential and Enhanced, on the example CCI product summary page.

Related

Sources

• FCA PS25/20: final rules for Consumer Composite Investments
• FCA Handbook: DISC 3, DISC 4.1, DISC 5, DISC 6, DISC 7
• FCA Handbook: COBS 4
• Simmons & Simmons: FCA CCI regime, 4 key updates
• K&L Gates: From UCITS KIIDs and PRIIPs KIDs to CCI product summaries

Important information

This checklist has been prepared with care and is believed to be accurate as at 8 October 2026, but it is a general summary only and may not be complete. It is not legal, regulatory or compliance advice and must not be relied on as such. Rules and regulators' interpretations change, and we do not undertake to keep this checklist up to date. Before relying on any point, check the current rules and take appropriate professional advice. To the extent permitted by law, autoFactsheet accepts no liability for any loss arising from reliance on this checklist; see our Terms and Disclaimer. If you spot something that is out of date, please let us know at info@autofactsheet.com.