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The FCA wants to blow up the way investment costs get explained to ordinary people. Plain English, fewer layers of jargon, and a unified framework — that’s the pitch. And it’s coming whether firms are ready or not.
The regulator put out a consultation — CP26/24 — that would fold investment cost disclosures into its existing product disclosure reforms, building one joined-up system rather than the patchwork that’s been sitting there for years. The goal is pretty straightforward: make it easier for consumers to compare products, understand what they’re actually paying, and invest with some degree of confidence instead of confusion. Lucy Castledine of the FCA put it plainly — the whole point is to give consumers the information they need to make real decisions. Not technically-compliant disclosures buried in a 40-page document, but actual usable information. Distributors will have to show their own costs sitting right next to product costs, formatted in line with the Consumer Composite Investments model, known as CCI. Firms will also need to disclose fees or interest charged on client cash. No more hiding that in a footnote.
Around 30% of non-advised platform users have no idea what fees they’re paying.
That number is pretty damning. These aren’t people who ignored a warning — they just never got one in a form they could understand. The FCA’s review of current disclosure documents makes that gap concrete: out of 132 pre-sale documents assessed for readability, only 6% were written in plain English. Six percent. Most of the rest were written beyond GCSE level, which means a significant chunk of the investing public is basically locked out of understanding the product they just bought.
The CCI Model Replaces PRIIPs and UCITS
The CCI framework replaces the existing PRIIPs and UCITS disclosure documents that firms have been using up to now. Those formats were always a bit clunky — designed more for regulatory box-ticking than actual consumer comprehension. CCI gives firms more flexibility in how they present information, which sounds like a small thing but probably isn’t. When you’re forced into a rigid template, the result tends to be dense, formulaic, and basically unreadable. Giving firms room to communicate in ways that actually land with their clients is the structural shift here.
June 2027 is when compliance becomes mandatory. That’s the hard deadline. Firms will be required to follow the CCI rules finalized last year, which means changes to how investments get explained to consumers before they buy. There’s no grace period floated beyond that date, and the FCA hasn’t suggested it’s in the mood to extend it.
The consultation is consistent with the FCA’s Consumer Duty framework and ties back to the 2023 Dear CEO Letter, which specifically touched on interest disclosures on cash and fee structures. So this isn’t coming out of nowhere — it’s been building for a while, and firms that weren’t paying attention to those earlier signals are probably scrambling now.
Industry Has Until August 21 to Respond
Stakeholders have until August 21 to send feedback on CP26/24. The FCA says it’ll keep working with the industry as the rules get finalized, but the direction of travel isn’t really up for debate at this point. The framework exists. The deadline exists. The consultation is about the details, not the destination.
What’s still unclear is exactly how the FCA will handle firms that technically comply but produce disclosures that are still effectively unreadable — formatted correctly but stuffed with financial terminology the average person won’t parse. The rules mandate plain English in principle. Whether the enforcement teeth match that ambition is a different question, and the FCA hasn’t been specific there yet.
It’s also worth noting what this means for the broader market structure. Platforms, wealth managers, and financial advisers all face different operational realities. A large platform with a dedicated compliance team can probably absorb these changes without too much pain. Smaller firms, maybe not so easily. The FCA says it’s working closely with industry to smooth the transition, but the specifics of that support haven’t been spelled out in detail.
The readability problem isn’t unique to the UK. Across developed markets, regulators have been wrestling with the same basic tension: financial products are complicated, but the people buying them often aren’t financial professionals. Disclosure documents that meet legal requirements but fail the comprehension test have been a persistent issue. The FCA is basically betting that mandating plain English at the regulatory level — and building it into the CCI framework structurally — will force a change that voluntary best practices never managed to produce.
Whether that bet pays off depends a lot on how seriously firms take the spirit of the rules, not just the letter. The 6% plain English figure from the current review is a baseline. The FCA will presumably run similar assessments after June 2027 to see if that number moves.
At this stage, the FCA hasn’t offered further comment on how the proposal progresses from here.
Frequently Asked Questions
What is the FCA’s CCI model and when does it take effect?
The Consumer Composite Investments model replaces existing PRIIPs and UCITS disclosure documents, with mandatory compliance starting June 2027. It requires firms to present investment costs in plain English alongside the CCI framework.
What did the FCA’s readability review find?
Out of 132 pre-sale investment disclosure documents reviewed, only 6% were written in plain English, with most exceeding GCSE reading level.
