CCIs Implementation Working Group

Background and Purpose

The FCA has adopted new disclosures rules that apply to retail investments. The rules apply to Consumer Composite Investments (CCIs) and seek to increase consumer engagement and understanding.

These changes impact the whole distribution change and come into effect on 8 June 2027.

In addition, the FCA will also consult on MiFID disclosure rules. These changes will also require industry-wide collaboration to ensure a smooth implementation.

TISA has convened this Working Group to draw together the TISA membership, which spans the full distribution chain, including manufacturers, distributors and data vendors. The group is working collectively to facilitate shared understanding of requirements and a smooth implementation of the new disclosure requirements.

The aim is to ensure that firms have early visibility, practical solutions, and a strong, coordinated industry voice as regulatory expectations continue to evolve.

Areas of focus

The CCIs Implementation Working Group has the following areas of focus:

1. Developing an indicative, industry‑aligned CCIs implementation timeline
2. Shaping machine‑readable disclosure standards that work at scale
3. Aligning data and disclosure requirements across manufacturers, distributors, and platforms
4. Considering updates and changes to data templates (including EMT/EPT) to ensure operational workability
5. Coordinating closely with related initiatives, including FinDatEx’s review of EMT and EPT
6. Providing unified, informed input into FCA engagement (roundtables and papers)

Structure of Meetings

The CCIs implementation Working Group is currently meeting on a weekly basis to progress data template requirements, timeline expectations and a shared understanding of FCA requirements.

The TISA lead in this area is Sophie Legrand-Green, Head of Policy – Consumer Protection & Access

Achievements of the Group

FinDatEx has announced its intention to review both the EMT and EPT in response to the new CCIs regime. Their update can be found here:
https://extranet.findatex.eu/news/90/upcoming-review-of-emt-ept-in-relation-to-the-uk-fca-s-cci-rules

We expect FinDatEx to consult on the new template towards the end of October, with a view to finalising the template in early-2027, once the FCA’s cost and charges rules are finalised.

The WG continues to monitor developments and assess implications for UK‑specific templates and data exchange standards.

TISA responded to the FCA’s consultations on the new pre-sale disclosures regime for CCIs. In line with TISA’s research findings, we called for the FCA to undertake a holistic review of disclosures. The review should consider pre and post-sale disclosures for consumer investments and should seek to improve intelligibility, accessibility and engagement. Consistency across disclosures must be a priority to drive up trust and suitable comparability. The TISA response to FCA CP 24/30 is available here and the TISA response to FCA 25/9 is available here

TISA has also responded to the FCA’s consultation on simplifying cost and charge disclosures. In the response, we continue to encourage the FCA to prioritise consistency across CCI disclosures and to encourage consumer confidence and trust. The TISA response to FCA CP 26/24 is available here

TISA has responded to the proposed clarifications to the CCIs regime in FCA QCP 26/32. We have urged the FCA to take a more considered and nuanced approach to consistent past performance disclosures, in order to prioritise consumer understand and informed decision making. The TISA response to FCA QCP 26/32 is available here

A J Bell
Aberdeen Group
Aegon UK PLC
Allfunds Bank S.A.U
Apex Fundrock
Ascentric
Aviva UK Insurance
Bank J. Safra Sarasin (Gibraltar) Ltd
Barclays
Blackrock Investment Management (UK) Limited
Canada Life Ltd
Capital Group
Charles Stanley & Co Ltd
Columbia Threadneedle Investments EMEA
Digital Moneybox Ltd
Euroclear SA/NV
FE Fundinfo
Fidelity International
FNZ
Hargreaves Lansdown
Interactive Brokers (U.K.) Limited
Invesco
Janus Henderson

JPMorgan Chase
Jupiter Asset Management
KNEIP
Legal & General
LGT Wealth Management UK LLP
Liontrust Asset Management Plc
M&G
Margetts Fund Management Ltd
Meteor Asset Management Limited
MFS International (UK) Ltd
Morningstar UK Ltd
ONE Group Solutions
Parmenion Capital Partners
Quilter PLC
Rathbones Group Plc
Schroders PLC
Simmons & Simmons
St James’s Place Wealth Management
Triodos Bank NV
Valu-Trac Investment Management Limited
Vanguard Asset Management Ltd
Waystone

Sophie Legrand-Green, Head of Policy: Consumer Protection & Access leads on this work

Chairs: Sarah Dobbs, Aegon and Patrick Hehir, MFS

 

Publications

News