Financial Conduct Authority consults on further CCI disclosure proposals covering transaction cost methodology and transition rules

The Financial Conduct Authority (FCA) published Consultation Paper CP25/9 with additional proposals to support the forthcoming Consumer Composite Investments (CCI) product information regime, focusing on cost disclosures and how firms move from current disclosure requirements into the new framework. The consultation proposes removing the requirement to calculate and disclose implicit transaction costs, including the slippage methodology, while retaining disclosure of explicit transaction costs such as broker fees, exchange fees and stamp duty, including in the summary cost figure and based on a 36-month average (or a reasonable estimate for newer products). It also sets out draft changes to align Markets in Financial Instruments Directive (MiFID) Organisation Regulation-derived cost disclosure rules with CCI disclosures, including a rewrite of Article 50 requirements and deletion of Article 51 to avoid duplication. For the transition period, manufacturers would be able to continue using existing disclosure documents (such as PRIIPs and UCITS disclosures) or switch to the CCI product summary when ready, with consequential FCA Handbook amendments and simplified complaints handling requirements proposed for certain unauthorised CCI manufacturers. The consultation closes on 28 May 2025. The FCA intends to respond to feedback on CP25/9 and its earlier CCI consultation (CP24/30) together in a single policy statement with final rules in late 2025, and expects to adjust the implementation timeline so the regime comes into force for all firms at the same time.