CCI is a Judgement Framework, not a Template Exercise

This article was developed jointly by FundSense and Investment Solutions Consultants (ISC), reflecting the strategic and operational perspectives we are seeing in early Consumer Composite Investments (CCI) discussions across the market. 

Most firms preparing for the Consumer Composite Investments regime believe they understand what the rules require. In technical terms, they usually do. 

The uncertainty does not lie in the regulation itself. It lies in what the regime demands of internal decision-making. 

In recent discussions with firms across the market, one theme has been consistent: CCI is less a drafting exercise and more a test of judgement. Once prescriptive templates fall away, the real questions surface, who decides, on what basis, and how that decision is evidenced if challenged by the Financial Conduct Authority or a distributor downstream? 

That shift changes the nature of implementation. 

Take timing. Many firms are debating whether to move early and avoid repeated UCITS or PRIIPs updates, whether to run regimes in parallel to test and learn, or whether to wait until closer to the June 2027 deadline when market practice may be clearer. 

There is no single correct answer. But there is a flawed approach: treating timing as an administrative scheduling choice rather than a risk decision. Each path carries different exposure: re-work risk, comparability risk, governance strain or supervisory scrutiny. 

The firms best positioned are not those moving fastest or slowest, but those able to articulate why they chose their approach and how it will be reviewed as conditions evolve. Without that clarity, firms may struggle to explain the rationale behind their disclosures if challenged by the Financial Conduct Authority or questioned by distributors downstream. 

In practice, this can be as simple as documenting why a firm chose to run PRIIPs and CCI disclosures in parallel for a transition period, or why it decided to redesign disclosures entirely rather than adapt existing templates.  

A similar pattern appears in the debate over reuse versus redesign. Estimates of overlap between existing PRIIPs disclosures and CCI range from 30% to 70%, particularly where EU-domiciled funds distributed into the UK must continue producing KIDs. But the more useful question is not how much content can be recycled. It is whether that content still supports consumer understanding under a different regulatory philosophy. 

Some firms are discovering that starting conceptually with a blank page, even if they later reintroduce selected elements, produces more coherent outcomes than trying to retrofit a new regime onto old assumptions. 

The most significant shift, however, is organisational. CCI’s flexibility inevitably draws Marketing and Distribution teams closer to disclosure production. The document begins to feel more like a factsheet than a legal artefact. That has clear advantages for clarity and plain English communication. It also changes ownership. 

Where Compliance historically “owned” disclosure, CCI encourages shared accountability. Language becomes strategic. Presentation begins to shape behaviour. Governance must stretch across functions that have not traditionally co-owned regulated documentation. Firms that acknowledge this explicitly and design operating models around it are making faster progress than those attempting to preserve legacy silos. 

Flexibility creates further tension. In the absence of a prescribed format, firms are free to innovate. But flexibility without coordination risks friction. Distributors are not currently imposing a single standard. Vendors may offer templates. In this vacuum, manufacturers can either lead with a coherent, layered structure that works digitally and on paper or respond reactively once downstream expectations harden. 

The same principle applies to data. Machine readability is required, but implementation choices vary. For some firms, structured metadata embedded within disclosures may provide sufficient control. For others, separate data outputs may be preferable. What matters is not the format itself, but whether the approach is intentional, defensible, and operationally sustainable. 

Across early movers, a pattern is emerging.  

The firms navigating CCI most confidently are not those producing the most polished specimen documents.  

They are the ones that have agreed how judgement will be exercised, clarified cross-functional ownership, designed layered disclosures where the front layer stands alone yet aligns with deeper detail, and built mechanisms to detect and respond to change consistently. 

CCI does not demand perfection. It demands coherence. 

Firms that approach it as a document exercise may meet the letter of the rules. Firms that treat it as an opportunity to strengthen governance, simplify product explanation, and clarify accountability are more likely to meet the regulator’s intent; thereby avoiding the slow erosion of control that follows from poorly aligned decisions. 

In practice, successful CCI implementation appears to depend on two disciplines working in tandem: clear strategic decisions around ownership, judgement and governance, and controlled production that ensures data, documents and machine-readable outputs remain aligned over time. In many organisations these disciplines are still handled sequentially, or by different teams. When they are designed together from the outset, the regime becomes far more manageable. When they are separated, friction tends to follow, often gradually, and expensively. 

We invite you to connect with us to continue this conversation. Let's explore how FundSense can help you address CCI in your organisation.