The Financial Conduct Authority (FCA) is spearheading a transformation of the UK’s disclosure regime for Consumer Composite Investments (CCIs), a vital asset class encompassing investment funds, structured products and insurance-based investments. With the dual publications of CP24/30 and the follow-up CP25/9, the FCA is laying the groundwork for a modern, flexible and consumer-centric disclosure framework designed to enhance investor confidence and improve market outcomes.
This reform represents more than a technical regulatory change, it marks a strategic evolution in how investment products are communicated to better support informed decision-making.
CP24/30: Building a New Product Information Framework
Published in December 2024, CP24/30 marked a bold step towards overhauling the existing disclosure regime, which the FCA had previously described as overly complex, inflexible and poorly aligned with consumer needs.
The current framework, inherited from the EU (notably PRIIPs and MiFID II disclosure requirements), has long been criticised for prioritising standardisation over consumer comprehension. Consumers often receive dense documents filled with jargon and data and yet remain no better informed. CP24/30 addressed this issue by proposing a principles-based, outcome-focused regime that enables firms to tailor product information to the needs and context of their clients.
Key Objectives of CP24/30:
- Empower consumers with clearer and more relevant product information.
- Enable flexibility for firms to innovate in how they present investment disclosures.
- Promote competition by allowing differentiation through better communication.
- Strengthen trust in the retail investment market by ensuring consumers understand the value and risks of what they are purchasing.
CP25/9: The Next Step in Delivering Better Outcomes
In April 2025, the FCA published CP25/9, providing further clarity and complementary proposals to complete the reform initiated in CP24/30.
While CP24/30 set out the overarching vision, CP25/9 delves into the practical implementation of the new regime. It focuses on cost disclosure, transitional arrangements and FCA Handbook amendments to ensure deliverability and regulatory coherence.
Highlights of CP25/9:
- A new methodology for calculating transaction costs, replacing the controversial ‘slippage cost’ approach. The FCA proposes a more intuitive alternative that reflects actual costs to consumers more transparently.
- Amendments to cost disclosure rules under the MiFID Org Regulation, aligning charge presentation with the new outcome-focused principles.
- Transitional flexibility, allowing firms to adopt the new regime when ready, enabling innovation without facing regulatory penalties.
- Consequential updates to the FCA Handbook, particularly modules such as COBS 6, COBS 14 and PRIN, to reduce ambiguity and ensure consistency across disclosures.
Strategic Impact
Together, CP24/30 and CP25/9 represent a paradigm shift in financial services disclosure. These proposals don’t just rewrite the rules, they redefine the principles on which product communication is based.
For Consumers:
- Easier access to meaningful information such as product objectives, risk profiles, performance scenarios and total costs.
- Better tools for comparing investment options based on personal financial goals.
- Reduced dependence on intermediaries to interpret complex documents.
For Firms:
- Greater scope to innovate in disclosure design, including digital formats, interactive tools and layered content.
- A clearer, outcomes-based compliance framework that reduces the risk of regulatory breaches.
- Improved client engagement and trust through transparent communication.
What to do Next
The FCA is seeking industry feedback on CP25/9 until 28 May 2025, with a final Policy Statement anticipated later this year. This consultation presents a critical opportunity for firms, trade associations and consumer groups to help shape a regulatory regime that will govern trillions of pounds in retail investments for years to come.
How can Complyport Help
Complyport is uniquely positioned to support your firm in aligning with the FCA’s evolving product disclosure regime for Consumer Composite Investments. We offer:
- Gap Analysis and Regulatory Impact Assessment: Identify how your existing disclosures compare with the proposed frameworks in CP24/30 and CP25/9.
- Tailored Compliance Roadmaps: Practical guidance to support your transition to the new product information regime.
- Policy and Handbook Updates: Support in updating your internal policies and procedures in line with new FCA expectations.
- Training and Staff Awareness: Equip teams with the knowledge and resources to deliver against the FCA’s consumer outcomes agenda.
- Regulatory Engagement Support: Assistance in drafting consultation responses or preparing for regulatory engagement as final rules are shaped.
Book a Meeting with a Complyport SME
To understand how these reforms affect your business, and to get expert help on disclosure design and compliance planning, book a meeting with a Complyport Subject Matter Expert today.
Ask ViCA, your Virtual Compliance Assistant. Claim your complimentary 20 queries today! Register here: https://vica.chat
