UCITS KIIDs and the CCI Horizon: Preparing for the Next Chapter in Retail Disclosure

How asset managers can prepare for the transition from UCITS KIIDs to a new UK-specific retail investment disclosure regime, the Consumer Composite Investments (CCI) regime. 

The landscape of investor disclosure is shifting once again. For asset managers operating across Europe and the United Kingdom, 2025 marks a pivotal year. Bridging the sunset of the UCITS KIID regime, the PRIIPs framework in the EU, and the rise of the UK’s new Consumer Composite Investments (CCI) framework. 

“The shift from UCITS KIIDs to the UK’s CCI framework is not just a regulatory milestone. It is a moment for asset managers to rethink how they manage and communicate data. Those that invest in automation today will be the ones who move fastest tomorrow”, says Jamie Keen, Founder and CEO, FundSense. 

The End of an Era for the UCITS KIID 

The UCITS Key Investor Information Document (KIID) has been a cornerstone of European retail disclosure for more than a decade. Designed to help retail investors compare funds easily, it brought structure and comparability but also rigidity. 

That era is ending. Since 1 January 2023, UCITS funds marketed to EU retail investors must now provide a PRIIPs KID instead of a UCITS KIID. The aim is to create a single, harmonised disclosure regime across packaged investment products. 

Meanwhile, the UK has taken a different path. Following Brexit, the FCA extended the UCITS exemption, allowing firms to continue issuing UCITS KIIDs to UK retail investors until 31 December 2026. After this date, KIIDs will be replaced by the new Consumer Composite Investments (CCI) framework, forming part of the UK’s post-Brexit disclosure regime. 

The UK’s Next Step: Consumer Composite Investments (CCI) 

The CCI regime represents a complete rebuild, not an adjustment, of the UK’s retail disclosure model. Rather than adapting PRIIPs, HM Treasury has established the legislative framework for the CCI regime, and the FCA is developing the detailed rules, consultations, and product information requirements under that framework. 

The new structure centres on two connected layers of disclosure: 

• Product Summary: A short, plain-English document (two to three pages) featuring a clearer 1–10 risk scale and line-chart performance data. 

• Manufacturer’s Core Information Disclosures: A deeper, technical layer designed for intermediaries, analysts and regulators, covering costs, governance, and performance data. 

Together, these layers aim to balance simplicity with substance, improving accessibility for retail investors while maintaining transparency for professionals. 

The timeline is now clearer: 

• Late 2025: FCA is expected to publish its final Policy Statement. 

• 2026–2027: Firms enter an 18-month implementation period. 

• 31 December 2026: UK UCITS KIID exemption ends. 

• By 2027: CCI disclosures are expected to become mandatory for all UK retail funds. 

What This Means for Asset Managers 

For now, firms must operate under dual disclosure regimes: 

• EU retail investors: PRIIPs KID 

• UK retail investors: UCITS KIID (until CCI applies) 

This duality introduces operational friction. Different templates, risk methodologies, cost disclosures, and file formats all must be produced, reviewed, and distributed in parallel, often under tight reporting deadlines.  

With the forthcoming expanded 1–10risk scale, line-chart performance presentation, and revised cost methodologies, the traditional, manual approach will not scale. “Operating under both PRIIPs and CCI regimes can feel like double the work. Our goal is to make it seamless: one golden source of data feeding multiple formats, so firms can meet every obligation without duplication,” says Martin Jones, Head of Document Solutions, FundSense. 

From Compliance Burden to Data Opportunity 

At FundSense, we believe the CCI transition is a catalyst for digital maturity. Rather than treating disclosures as static documents, firms can use this moment to build governed data frameworks that automatically generate compliant outputs. According to Keen, “Technology is no longer a nice-to-have in compliance. It is the bridge between transparency and trust. By connecting systems and data, firms can transform mandatory disclosures into meaningful communications that build investor confidence”.  

Key benefits of this approach include: 

• Consistency Across Markets: Data-driven templates enable firms to meet EU PRIIPs and UK CCI obligations from a single governed source. 

• Faster Turnaround: Automated validation, SRRI/SRI recalculation, and approval of workflows reduce production cycles dramatically. 

• Reduced Risk: Audit trails, version control, and automated checks ensure accuracy even as rules evolve. 

By embedding automation at the data layer, not just in document formatting, managers gain long-term control, flexibility, and assurance. 

The Road Ahead 

The next 12-18 months will bring final CCI rules, clarifications on cost disclosures, and practical implementation guidance. But the direction is already clear: investor disclosure is becoming more dynamic, visual, and data-centric. Says Jones, “Automation is not only about speed; it is about control. When you can trace every data point, every version, and every approval, compliance becomes far less reactive and far more strategic.” 

For asset managers, the key is readiness, not only to produce new formats but to connect systems and data, so every disclosure flows from a single, trusted source. As regulatory complexity grows, success will depend on viewing compliance as an enabler of confidence and technology as the foundation of trust. 

About FundSense 

FundSense provides intelligent automation for asset managers, enabling firms to manage, govern, and deliver compliant disclosures across jurisdictions with confidence. From UCITS KIIDs and PRIIPs KIDs to the future CCI framework, FundSense helps clients automate data validation, workflows, and document production, turning regulatory change into operational advantage. 

📧 info@fundsense.io 🔗 fundsense.io  To learn more, visit fundsense.io or speak with our team about preparing your disclosure environment for the CCI era.