PIMFA
PRODUCT DISCLOSURE
The FCA set out final rules for the new consumer composite investment disclosure framework in PS25/20: Supporting informed decision making: Final rules for Consumer Composite Investments. This policy statement summarises feedback to consultation papers issued in December 2024 and April 2025.
Following industry feedback and discussion, the policy statement includes clarification of the scope of the new rules, including the application to non-retail products. Concerns were raised about the level of information included both from the perspective of overwhelm and the need to have access to comprehensive information. The final rules include greater flexibility in how the product information is surfaced and a clear focus on helping consumers make timely, effective and informed decisions.
- SCOPE
The new regime introduces the concept of a consumer composite investment. This includes:
- Open ended funds
- Closed ended funds
- Recognised funds
- Structured products
- Structured deposits
- Contracts for difference
- Insurance based investment products
- Other complex products inc derivatives
Pension products, vanilla corporate bonds and pure protection contracts are specifically excluded from scope.
- Roles & Responsibilities
Manufacturers must create a consumer-friendly product summary. This must include comparable key information about costs, risk and return, and past performance. They have freedom over the design of the product summary. Manufacturers must also provide a machine-readable file to distributors containing this core information.
Distributors must make the product summary available to clients and highlight key information to help consumers make effective and informed investment decisions. Key information includes, a brief explanation of the product, the on-going costs figure of the product, and other costs relevant to the product, the risk and return score of the product and a brief explanation of the product’s risk and return profile, and any relevant warnings. They have the flexibility to provide information in ways that best support customer understanding. The product summary must be provided in a durable medium at the point of sale.
- Product Information
The volume of product information required from manufacturers is considerable. While the approach is intended to be flexible and straightforward, the mandatory information fields will inevitably produce a highly detailed document. The tables below detail the information that must be included in the product summary
- Transitional Arrangements
The legislation came into force in April 2026. After this date, manufacturers can choose to produce a product summary at any point. Where this document is produced, distributors must surface this document for any product sold. The rules come into force on 8th June 2027. By this date, manufacturers must produce product summaries for any consumer composite investment they manufacture and distributors can only distribute consumer composite investments with an accompanying product summary. Product data must be provided by the manufacturer to the distributor in a machine readable format. Distributors should use this information to make their customer journeys accessible and to ensure key information is surfaced at appropriate times.
latest news
MiFID Costs & Charges
We have consistently called for an urgent review of the existing MiFID costs and charges disclosure requirements. In our view, this review should have been undertaken as part of the wider reform of the disclosure framework. Encouragingly, a review is now underway, and we are working alongside other trade associations to advocate for the following key principles:
- Clear, decision-useful information: We believe consumers would benefit from more targeted disclosures that are readily understandable and provide practical value in supporting informed decision-making.
- Alignment with the CCI framework: In particular, alignment in the treatment and presentation of ongoing and one-off cost figures will be critical to ensuring consistency and reducing consumer confusion.
- Removal of cumulative cost disclosures: We consider the current cumulative cost disclosure requirements to present an unbalanced and potentially misleading view of the impact of costs on investment returns.
- Coordinated implementation: We are calling for MiFID reforms to be implemented in parallel with the CCI regime, or for appropriate regulatory forbearance to be provided, in order to avoid unnecessary complexity and operational burden for firms.
A consultation paper is expected to be published in early summer.
- CCI Implementation Working Group
PIMFA has established an implementation Working Group to facilitate engagement across member firms, with the aim of supporting consistent interpretation, sharing emerging challenges, and agreeing best practice throughout the implementation process. We are also working closely with other trade associations to ensure effective information-sharing between manufacturers and distributors, and to coordinate the dissemination of guidance received from the FCA.
If you would like to join the working group and keep up to date with these developments, please contact Julia Sage-Bell.
