On 2 July 2026, the UK Financial Conduct Authority (FCA) published Consultation Paper CP26/24, Simplifying Consumer Investment Disclosures. The consultation proposes new rules for how firms—including investment platforms, financial advisers, and execution-only distributors—communicate investment costs to retail clients, bringing these disclosures into alignment with the Consumer Composite Investments (CCI) framework introduced in Policy Statement PS25/20.

The consultation is open for industry feedback until 21 August 2026, with the regulator expecting to publish its final rules by the end of the year. Crucially, the core implementation timeline and the 8 June 2027 go-live date for the mandatory CCI regime remain fixed and are unaffected by these proposals.

Alongside the consultation, the FCA has released a separate multi-firm review assessing current pre-sale disclosure documents, which highlights systemic readability issues to assist firms in optimising consumer documentation before the 2027 implementation deadline.

What the FCA is Proposing

The consultation is designed to update the broader cost disclosure rules—primarily the older frameworks inherited from MiFID—and merge them cleanly into the new CCI architecture. The regulator plans to consolidate the currently fragmented disclosure rules across MiFID, insurance distribution (IDD), and non-MiFID business into a single, unified chapter of the Conduct of Business Sourcebook: COBS 6A. This consolidation alters the operational tracking for firms by removing parallel compliance streams and data mapping previously required to meet near identical retail requirements across different business lines.

The substantive changes focus on how costs are structured and presented:

  • Pre-Sale Presentation: At the point of sale - for example, where platforms and advisers publish their charging structures on their websites or in client illustrations - distributing firms will be required to show a consolidated figure representing the total of all ongoing product costs combined with the firm’s own service and distribution fees (such as platform, advisory, and dealing charges). Other distinct cost elements—including one-off entry/exit fees, transaction costs, performance fees, and underlying closed-ended fund costs—must be explicitly unbundled and shown separately rather than aggregated into a single headline percentage.
  • Post-Sale Reporting: Firms will continue to provide a periodic breakdown of the actual costs paid by the client, which must be expressed both as a cash amount (in pounds and pence) and as a percentage (relative figure) of the investment. However, distributors will gain new flexibility to layer and structure these statements visually - for example, by grouping ongoing charges to mirror the pre-sale layout before displaying irregular costs.
  • Abolition of Cumulative-Effect Illustrations: The FCA proposes to remove the requirement for personalised, forward-looking cumulative-effect illustrations across both pre- and post-sale environments. While fund manufacturers were already freed from rigid forward-looking templates under the core CCI rules, investment distributors and platforms remained technically bound to generate these calculations under parallel MiFID provisions. This proposal eliminates that final mismatch, addressing the long-standing regulatory concern that unprescribed methodologies led to inconsistent and potentially misleading projections for consumers.
  • Interest on Client Cash: The proposals codify the FCA’s long-standing regulatory position regarding client money balances. Firms must deliver clearer, prominent up-front disclosures regarding how interest rates on cash are calculated. Furthermore, the rules officially prohibit the practice of “double dipping,” meaning a firm cannot charge an administrative fee on cash balances while simultaneously retaining the interest earned on those holdings.

Relevance for Template-Based Reporting

The operational consequences of CP26/24 will flow directly through the standardised data templates the industry relies on to exchange product and cost data—most notably the European MiFID Template (EMT) and European PRIIPs Template (EPT).

The consultation paper is explicit on this front, directly referencing FinDatEx and confirming that revised versions of the EMT and EPT are planned for early 2027. These template changes are required to accommodate the structural UK data updates previously established by the underlying CCI rules ahead of the June go-live.

Significantly, the FCA notes that this consultation itself should not require any further fields or modifications to the EMT data fields. The necessary underlying cost categories match what the CCI rules already put in place. Instead, these new proposals simply alter how distributors aggregate and calculate those numbers using the data fields already provided by the template.

The consultation addresses practical data quality challenges directly. Intermediaries and platforms frequently struggle to collect precise, actually incurred cost data across the distribution chain due to misaligned reporting cycles and fragmented vendor services. To resolve this, the FCA proposes to permit a “reasonable estimate of actually incurred costs” where sourcing exact calculations would demand a disproportionate compliance effort. Crucially, the regulator expects firms to utilise the same underlying dataset to fulfil both their CCI product descriptions and post-sale periodic disclosures.

A Pragmatic Transition for Manufacturers: For asset managers and fund manufacturers navigating the implementation timeline ahead of the 2027 go-live date, the FCA clarifies the transitional mechanics in paragraphs 4.40–4.42. During this interim phase, distributors are permitted to continue providing existing PRIIPs KIDs or UCITS KIIDs to retail investors, even if a manufacturer has elected to adopt the new CCI product summary early. Crucially, manufacturers will not be legally required to update legacy KIDs/KIIDs during this transition window unless a material change is made to the fund’s objectives, investment strategy, or risk-return profile. This practical buffer reduces operational friction and provides welcome breathing room across the product manufacturer landscape.

Looking Ahead

CP26/24 represents the practical implementation phase of the UK’s broader disclosure reform. While the format for the fund-level CCI product summary was already settled in PS25/20, the practical mechanics of how distributors and platforms must calculate, aggregate, and display those figures on their own interfaces are being finalised now. With final rules due by the end of 2026 and an 18-month transition window running through to the final compliance deadline in June 2028, few firms are treating these upcoming process changes lightly.

Two aspects of this paper are particularly welcome from a regtech perspective:

  1. Industry Template Recognition: Acknowledging the existing data standards by explicitly referencing FinDatEx templates indicates that the FCA has practical market implementation in mind—a structural reality that is all too often missing in wider regulatory design.
  2. Proportionate Cost Analysis: The cost-benefit analysis estimates around £20.1m in one-off transition costs across roughly 5,300 affected firms. While this represents a notable upfront commitment, the FCA notes that the investment pays off over time. The long-term gains in operational efficiency and reduced regulatory complexity—achieved by ending duplicative compliance processes, removing cumulative impact calculations, and gaining flexibility with professional clients—are expected to progressively offset these implementation costs.

At SolvencyAnalytics, we closely monitor FinDatEx template developments alongside the evolving UK and EU disclosure frameworks. If you would like to exchange views on the CCI regime, its data challenges, or the forthcoming EMT/EPT revisions, please get in touch with our team at info@solvencyanalytics.com.