The CCI product summary: a Consumer Duty test for payment-firm distributors
In short: The CCI product summary is the FCA’s new disclosure document for retail investment products, replacing the EU-derived Key Information Document. Under FCA PS25/20, firms can adopt it from 6 April 2026 and must use it from 8 June 2027. Whether to switch early is a Consumer Duty question, not a technical compliance one.
From PRIIPs KID to CCI product summary
If a firm sells retail investment products in the UK, including funds, structured products, ISAs sitting alongside an account, or anything where the customer’s return depends on how an underlying investment performs, the disclosure document it gives the customer is changing. The standardised Key Information Document inherited from EU rules is being replaced by a UK-designed product summary calibrated to the FCA’s Consumer Duty. Firms have a 14-month window, from 6 April 2026 to 8 June 2027, to make the switch.
Policy Statement PS25/20, published by the FCA on 8 December 2025, sets the final rules for the new regime, which carries the formal name Consumer Composite Investments (CCIs). The amendment SI commencing the optional transition is SI 2025/1347. CCIs are the most visible point so far at which two FCA workstreams converge: the Consumer Duty rebuild of the FCA Handbook, and the Smarter Regulatory Framework removal of inherited EU instruments.
Regulatory background
The PRIIPs Regulation (assimilated EU Regulation 1286/2014) and the UCITS KIID have governed retail investment product disclosure in the UK since the late 2010s. Both prescribed templates: the PRIIPs KID is a three-page document with a fixed section structure, prescribed risk indicator and prescribed performance scenario methodology. The UCITS KIID is two pages with a different prescribed structure and a synthetic risk indicator. Manufacturers had little room to vary either form.
The Financial Services and Markets Act 2023 revoked the PRIIPs Regulation as part of the wider Smarter Regulatory Framework programme. The Consumer Composite Investments (Designated Activities) Regulations 2024 (SI 2024/1198) designated CCI activity for the purposes of FSMA 2000, putting the FCA in a position to make the substantive Handbook rules under FSMA 2000 s.137A. SI 2025/1347 (the Amendment Order) commences the PRIIPs revocation and the new designated activity on 6 April 2026.
PS25/20 is the policy statement responding to two consultations: CP24/30 (the substantive product information framework) and CP25/9 (transitional provisions, transaction-cost methodology and consequential Handbook amendments). CP25/9 closed on 28 May 2025; PS25/20 closes both consultations.
What the CCI product summary actually changes
The CCI product summary is shorter on prescription than either of the regimes it replaces. The Handbook (the new COBS chapter inserted by FCA 2025/52) prescribes the format and methodology only for three areas: cost disclosure, risk indication, and past performance. Everything else, including layout, length, ordering, design, choice of headings and integration into a digital journey, is for the manufacturer to design, subject to the Consumer Duty.
That last clause matters more than it sounds. A PRIIPs KID was a compliance artefact: produce the document in the prescribed form and the firm’s PRIIPs disclosure obligation was met. The product summary is not an artefact; it is the output of a Consumer Duty governance process. PRIN 2A.5 (consumer understanding outcome) requires firms to communicate in a way the target market can actually understand, and PRIN 2A.6 requires manufacturers to share product information with distributors so that distribution arrangements stay consistent with fair value being delivered. The product summary is the document through which both of those obligations are delivered to the customer.
Manufacturers therefore inherit two new questions the PRIIPs regime did not pose. First, whether the design of the summary supports comprehension by the identified target market, measured against the manufacturer’s own product testing and customer research, not by reference to a template. Second, whether the summary, the underlying fair value assessment and the distributor information pack are mutually consistent. The summary is evidence of a Consumer Duty-compliant design process, not a substitute for one.
Implications for payment-firm distributors
A subset of FCA-authorised payment institutions and e-money issuers also distribute CCIs: investment-embedded current accounts, ISA wrappers offered alongside payment accounts, white-label structured product distribution and platform-level fund supermarkets. Those firms read the regime through their distributor lens, not through their PSR/EMR authorisation lens. The wider payments fintech sector shares the same architecture wherever an investment product is bolted onto an account.
PRIN 2A.6 requires distributors of CCIs to confirm that the manufacturer has carried out a value assessment, to understand the assessment, and to ensure their own distribution arrangements do not undermine it. Where a payment-firm distributor charges fees on top of the manufacturer’s price, it must conduct its own value assessment in respect of those charges and the cumulative customer outcome. The product summary is the document on which the distributor’s confirmation of the manufacturer’s analysis substantially rests.
The transition window between 6 April 2026 and 8 June 2027 puts a live decision in front of every CCI distributor. Two factors point to early adoption. The first is operational: a single transition is cheaper than a long period of running PRIIPs KIDs in parallel with product summaries on different products in the same distribution book. The second is supervisory: the FCA’s January 2026 Enforcement Watch confirmed six open Consumer Duty investigations focused on the price and value outcome, predominantly on outlier firms. Issuing inherited PRIIPs documentation through the late stages of the transition risks looking like an outlier on consumer understanding.
Two factors point the other way. Payment-firm distributors that already invested heavily in Consumer Duty disclosure for their payment accounts have most of the design work done; those still relying on legacy product committees will find the build cost material. And firms with PRIIPs-only product books at the margin of their offering may judge that running the inherited documentation to expiry is the cheaper outcome.
For acquirers and investors looking at fintech M&A in the embedded-investment space, regulatory due diligence in the period to 8 June 2027 will turn on the target’s product summary roadmap and the underlying Consumer Duty governance process, not on the standalone PRIIPs compliance position. The latter is a depreciating asset. Our payments product, safeguarding and scheme governance page sets out the standard scope for diligence on FCA-authorised distributors of payment and investment products.
Viewpoint
PS25/20 is the second visible move (after the Consumer Duty itself) by which the FCA is replacing prescriptive EU-inherited disclosure regimes with outcomes-based rules calibrated to PRIN 2A. The earlier FCA safeguarding supplementary regime followed a similar architecture: a removal of inherited EU detail, replaced with rules anchored on the Consumer Duty outcomes. The wider direction of travel is set by the PSR-FCA consolidation and the FCA’s 2025/26 work programme, which together point toward a Handbook calibrated more uniformly to PRIN 2A.
For payment-firm distributors of investments, the Consumer Duty governance maturity question matters more than the formal transition decision. Firms that have built fair value assessment frameworks for their payment products in 2024 and 2025 already operate the apparatus that the product summary requires. In our experience, the binding constraint on early adoption is rarely the document design; it is whether the distributor’s existing customer-outcomes management information is detailed enough to support the consumer-understanding evidence base the product summary now sits on top of. That is the diagnostic question for any CCI distributor weighing the transition.
Get advice
For advice on how the FCA’s CCI regime intersects with payment-firm distributor obligations under the Consumer Duty, contact Rob Bratby at Bratby Law. Bratby Law acts for FCA-authorised payment institutions, e-money issuers and the investment platforms that sit between them.
