In December 2024, the FCA published a consultation paper, CP24/30 proposing a replacement for PRIIPs and the KID.

The consultation proposes a new category of investment, the Consumer Composite Investment. This is a structured deposit, a security or financial instrument which is or embeds a derivative, or which includes features equivalent to a derivative contract, a debt security, a security issued by a fund, or rights or interests in such a security, a contingent convertible security, a contract for difference, an insurance-based investment product, and any other investment where the returns are dependent on the performance or changes in the value of indirect investments.

The proposed regime requires pre and post sale disclosure via a Product Information Summary document. Manufacturers must produce this document and also make core information available to distributors to allow them to enhance, amend or create their own documents. Although the presentation of the document is not templated, the content is heavily prescribed and is likely to result in a longer document than the existing PRIIPS KID.

PIMFA has responded to the FCA expressing concern about the narrow scope of the CCI regime given the breadth of the anticipated review and the interplay with MiFID which has not been considered. The new regime is due to come into effect in the summer of 2025 with an 18 month transition period for the majority of assets. This should align the new requirements with the end of the existing PRIIPS exemption for UCITS. These are tight timescales given the lack of detail in some area of the proposals and the strength of industry feedback. The full PIMFA response can be found here