On 9^th December 2025, the FCA published the long awaited new Consumer Composite Investment (CCI) rules, which will replace PRIIPs rules in the UK.

The document, which can be found here, covers a huge spread of investments. Importantly, it directly addresses and puts right the problem that has variously been referred to as ‘double counting’, ‘cost disclosure’ and ‘synthetic costs’.

As followers of the campaign will know, the problem has been that for years investors of all types have been obliged to add investment company expenses to their reporting as if they are directly chargeable to the shareholder. At last, it has been recognised that this doesn’t happen. Investors are not charged anything for holding shares in any company and for investment companies, expenses are not deducted from the share price, they are taken from the net asset value.

The improvements to the new CCI rules look remarkably simple, but they are incredibly important:

• There will be no requirement for funds that invest in investment companies to 'pull-through' investment company 'costs'. e.g. present them as if they are payable by the investor.
• Open ended funds, trackers and index funds, will all be treated in the same way (there had been a suggestion that the latter two would be exempted).
• Manufacturers will retain responsibility for calculating and publishing their own information and figures.
• KIIDs (UCIITs) and KIDs (PRIIPs) are of limited value and readership and will be replaced by a new publication called the Product Summary. It is anticipated that this new document will enable reporting of aggregated investment company holdings, their value, aggregate discounts/premiums which will facilitate clear and unambiguous reporting to investors.

Implementation for all investments regulated under CCI will have an implementation date in the summer of 2027, but any funds and investment companies that delay introducing the new rules will only be hurting themselves, so with luck, many will make the changes well ahead of that deadline.

While the new CCI rules are welcome, there is a snag. This is because the rules only apply to investors regulated under the CCI, such as open-ended funds. They don’t cover other market participants such platforms, wealth managers and advisers who are separately regulated under MiFID.

This group have had to publish misleading information for their clients for the last 8 years and for the time being, will have to carry on doing so until the MiFID rules are adjusted.

There is a MiFID review scheduled for 2026, so there is a reasonable chance it will be fixed. If it isn’t, we will have an untenable situation in which different types of shareholders will appear to bear different costs.

Gravis and the wider industry campaign group are confident a solution will be found to the MiFID problem and, all being well, this solution will coincide with the implementation of the CCI rules.

We will work with the parties involved to ensure that the correct information is available to all types of investors.

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