For over a decade, UK retail investors have relied on the UCITS Key Investor Information Document (KIID) or the PRIIPs Key Information Document (KID) to understand what they were buying.
Zeidler recently delved into the regulations and changes to the UK market. They were designed to give investors standardised, comparable information, but the Financial Conduct Authority (FCA) has now concluded, following extensive behavioural research, that the goal was never fully met. Many consumers simply didn’t engage with the paperwork, and those who did often found it hard to follow or of little practical use.
In response, the FCA’s Consumer Composite Investments (CCI) regime, confirmed in its final rules under PS25/20, will replace both the KIID and the UK PRIIPs KID with a single new disclosure: the Product Summary.
Zeidler notes that this is far more than a cosmetic redesign. It represents the most significant overhaul of UK retail investment disclosure since PRIIPs was introduced, and firms will need to revisit their data, calculation methods, governance and technology, not just their paperwork.
The most notable shift, according to Zeidler, is that there is no fixed template this time. Instead, the FCA has handed responsibility for document design to firms themselves, while still standardising the core metrics used to compare products: a new 1 to 10 risk and return score based on ten years of volatility data, a past performance graph tracking a £10,000 investment, and a five-category breakdown of costs and charges. Beyond these, firms have flexibility over layout, tone and format, provided the result genuinely helps retail investors understand what they’re buying, a requirement closely tied to the Consumer Duty framework.
The regime captures a broad sweep of products, from UCITS funds and investment trusts to structured products and contingent convertible securities, and applies regardless of where the manufacturer is based. As Zeidler points out, this creates a particular headache for cross-border managers, since the EU continues to use the PRIIPs KID, built on different methodologies entirely.
The transition period began on 6 April 2026, allowing voluntary adoption of the Product Summary on a product-by-product basis. From 8 June 2027, it becomes mandatory, and KIIDs and KIDs will no longer satisfy UK disclosure requirements. Zeidler suggests firms use this quarter to focus on scope, data and methodology, warning that those who leave preparation until 2027 risk having to implement new calculations, redesign disclosures and respond to distributor demands all at once.
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