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From PRIIPs KID to CCI product summary: a transition guide
The FCA's Consumer Composite Investments (CCI) regime replaces the UCITS KIID and the UK PRIIPs KID with a single product summary. Firms can switch now and must switch before the rules apply in full on 8 June 2027. This guide sets out the timeline, what changes, the data you will need and a practical plan to get ready.
Last reviewed 10 October 2026 · About 7 minutes to read
Please note: this guide 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 and take professional advice before relying on it. See our Terms and Disclaimer.
1. Key dates
| Date | What happens |
|---|---|
| 6 April 2026 | The legislation commenced and the optional transition began. Firms may publish CCI product summaries from this date, or keep using their existing KIIDs and KIDs. |
| Q1 2027 | A natural switching point for many UCITS, at the next annual KIID update. |
| 8 June 2027 | The rules apply in full. Existing KIIDs and UK PRIIPs KIDs must have been replaced by product summaries before this date. |
| Every 12 months after | Each product summary and its supporting data are reviewed at least yearly, and updated after any material change. |
The FCA describes this as an 18-month implementation period running from the policy statement (PS25/20) to the regime coming fully into force.
2. What changes from the KIID and KID
| UCITS KIID / UK PRIIPs KID | CCI product summary | |
|---|---|---|
| Format | Prescribed template: two pages (KIID) or up to three pages (KID) | No template and no page limit. Core figures are calculated to common standards so products can be compared |
| Risk | 1 to 7 scale (SRRI or SRI) | 1 to 10 risk and return score, based on the volatility of returns over 10 years; structured products use a value-at-risk method |
| Costs | Percentages (KIID) or cost tables over time (KID) | Gross costs shown as a percentage and in pounds on an assumed investment of £10,000, with ongoing, transaction, entry, exit and performance-related costs separated |
| Performance | Bar chart of up to 10 calendar years (KIID) or performance scenarios (KID) | Line graph of the value of £10,000 at each month-end over up to 10 years, net of costs, with a target or constraining benchmark where the fund has one. No performance scenarios |
| Data for distributors | EMT and EPT templates, by industry convention | A machine-readable Core Information Disclosure, plus the product summary and supporting information on target market, value and risks |
| Review | At least every 12 months | At least every 12 months, and after any material change |
3. Which products are in scope
A CCI is an investment whose return depends on the performance of underlying or reference assets. That covers investment funds, including UK UCITS, non-UCITS retail schemes and recognised overseas funds, as well as structured products, contracts for difference and other packaged products sold to UK retail investors. Ordinary company shares, plain listed bonds and pension schemes are outside the regime.
Funds recognised under the Overseas Funds Regime, such as Irish and Luxembourg UCITS ETFs sold in the UK, are included, and the FCA has confirmed the transition option is available to their manufacturers too. A fund sold in both markets may therefore need an EU PRIIPs KID and a UK product summary.
4. The data you will need
Most of the effort is gathering data once, then keeping it current. For each share class:
- Prices: weekly total-return NAVs for 10 years, or since launch, for the risk score. Monthly is allowed only where weekly prices are not reasonably obtainable.
- Missing history: for funds under 10 years old, the underlying index or reference asset levels for the years before launch, so the missing period can be simulated.
- Performance: month-end total-return NAVs and benchmark levels for the £10,000 graph.
- Costs: ongoing costs for the last 12 months, transaction costs for each of the last 3 years, maximum entry and exit costs, and any performance fee paid.
- Risk questions: liquidity and dealing terms, leverage, derivatives use and whether investors could lose more than they invest. These can move the score up from its volatility band.
- Product and contact details: objective, benchmark and its role, complaints details and the approving firm.
Much of this already exists in prospectuses, KIIDs, EMT files and administrator reports. Our CCI product summary checklist lists every requirement section by section.
5. A plan to get ready
- List the products in scope. Include every share class sold to UK retail investors, and recognised overseas funds.
- Choose when to switch. Many firms will align the switch with their next annual KIID or KID update. Switching early spreads the work; switching all at once keeps documents consistent.
- Collect the price and cost history. Weekly NAV history and three years of transaction costs are the items most often missing.
- Calculate the risk scores early. A fund whose volatility sits near a band edge, or that gains a point for illiquidity, may score differently from what you expect. Find out before it reaches distributors.
- Design the layout. There is no template, so decide on your format, branding and whether to offer a short and a fuller version.
- Set up the data feed for distributors. Prepare the machine-readable Core Information Disclosure alongside each summary.
- Agree approval and records. Decide who signs off each summary, and keep the risk score calculation and any adjustments on file.
- Update your factsheets. Switch UK factsheets to the new risk score at the same time as the product summary (see below).
6. What it means for your factsheets
A UK factsheet must be consistent with the key document. When a fund switches, its UK factsheet should show the new 1 to 10 risk score and match the product summary on charges, objective and benchmark. EU factsheets for the same fund keep the PRIIPs 1 to 7 indicator, so firms marketing in both markets will need separate UK and EU versions, or a clear explanation of both scores. Our guide Factsheet vs KID covers the consistency checks in more detail.
See our example CCI product summary for what the finished document can look like.
7. Common questions
Can we switch to product summaries before June 2027?
Yes. The optional transition began on 6 April 2026, so a firm can publish product summaries for some or all of its products now.
Is a product summary the same as a KID with a new name?
No. The risk scale, cost presentation and performance section all change, and there is no prescribed template. The underlying data overlaps, but the calculations need redoing.
Does every fund need 10 years of weekly prices?
The risk score uses 10 years of weekly prices where they are available. For younger funds, the missing years are simulated from the underlying index or reference assets, and only where that is not reasonably possible may an appropriate benchmark be used.
Who is responsible for the product summary?
The manufacturer, usually the fund's management company or the product issuer. Distributors must make the current version available to retail investors.
Related
Sources
- FCA PS25/20: Supporting informed decision making, final rules for Consumer Composite Investments
- FCA PS25/20 (PDF)
- K&L Gates: From UCITS KIIDs and PRIIPs KIDs to CCI product summaries
- FCA Handbook DISC 6.3 (costs)
Important information
This guide has been prepared with care and is believed to be accurate as at 10 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 guide 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 guide; see our Terms and Disclaimer. If you spot something that is out of date, please let us know at info@autofactsheet.com.
Free download: CCI readiness checklist
A two-page checklist of the dates, data and decisions needed to move from KIIDs and KIDs to CCI product summaries by 8 June 2027.
How ready is your firm? Answer 12 quick questions and get a readiness score, the effort ahead and your next steps for June 2027.
Getting ready for CCI?
We build CCI product summaries from your existing data, with every FCA rule checked and a rule checklist for your compliance file. Send us one fund and we will show you what its summary looks like.