The CCI Revolution: What New Disclosure Rules Mean

For advisers working with Structured Products and Structured Deposits, 2026 has already brought an important change in the way information about these products is presented to retail investors.  The UK’s new Consumer Composite Investments (CCI) regime came into effect on 6 April 2026 and is now bedded in with full implementation required by 8 June 2027.

Structured Deposits and Structured Products are explicitly within the scope of the new regime, with product-summary requirements forming an important part of the new disclosure framework.  For advisers, the significance goes beyond replacing one document with another.  The real opportunity is to consider whether the new approach can support clearer conversations with clients about how these products actually work.

The CCI regime replaces the UK’s previous PRIIPs framework.  One of the broader concerns with the previous regime was that highly standardised disclosures did not necessarily make complex investment products easier for consumers to understand. That challenge is particularly relevant to structured investments.  A structured product can have several moving parts: an underlying index, a barrier, a participation rate, an autocall feature, a maturity date and potentially a number of different outcomes depending on market performance.  Simply presenting the information in a standard format does not automatically make the product easy to understand.  The new regime is intended to provide a more flexible and useful approach to product information.

The precise terms of a structured product can make a significant difference to the outcome for the investor.  Two products might both advertise a potential return of 8%, for example, but one might require an index to remain above a particular barrier while another might have an entirely different mechanism.  This is why advisers should look beyond the headline return and understand the conditions that sit behind it.  The new product summary approach provides another opportunity to focus on the information that matters to the client’s decision.

Structured Deposits can be particularly confusing because the word “deposit” may lead clients to assume that they are simply another form of savings’ account.  The FCA defines a structured deposit as a deposit that is fully repayable at maturity, where the interest or premium is determined by a formula involving factors such as an index, financial instrument, commodity or foreign exchange rate.  That makes them fundamentally different from a conventional fixed-rate deposit.  The capital repayment feature and deposit protection arrangements are important characteristics, but the return is still dependent on specified conditions.  Advisers therefore need to ensure clients understand both what is protected and what is not.

The danger with any regulatory disclosure is that it becomes a compliance exercise rather than a communication tool.  For advisers, the more useful approach may be to use the product information as the starting point for a conversation.  Questions could include what determines the return, what happens if the underlying market falls, what happens if it rises significantly, whether the return is capped, what happens if the client needs their money before maturity, what risks remain despite any capital protection and how the product compares with simpler alternatives.  These questions can help move the conversation away from “What is the return?” towards “What outcome are we trying to achieve?”

The CCI changes also sit within the wider Consumer Duty framework.  For advisers, that means continuing to consider whether the product provides appropriate value for the intended client, whether the client can understand the product and whether the overall recommendation is consistent with their needs and circumstances.  The FCA has previously highlighted the importance of target-market identification and product governance in relation to structured products.  In other words, better disclosure should complement, rather than replace, good advice.

Now that the new regime is established, advisers have had several months to become familiar with the documentation and the way providers present structured products and structured deposits.  Rather than treating the new product summary as another document to file, advisers can use it to build a consistent process around product comparison and client understanding.  A useful approach is to understand the product, understand the client, model the possible outcomes, consider alternatives, explain the risks and document the rationale.

The transition to the CCI regime represents more than a regulatory change.  For structured products in particular, it provides an opportunity to improve the way complex investment outcomes are explained to clients.  The advisers who can translate product mechanics into clear client outcomes will be better placed to demonstrate both suitability and understanding.  Ultimately, the goal should be simple, not more information for clients, but better information that helps them make better-informed decisions.

Structured Products offer precision that conventional investments cannot match and the CCI regime helps advisers explain that precision in ways clients can actually understand.