The Consumer Composite Investments (CCI) regime – the UK Financial Conduct Authority’s new single retail disclosure framework – is set to come into force on 8 June 2027. That leaves firms with just under nine months to work out how to comply with the new regime.
That’s why on 10 September The Wealth Mosaic convened a webinar discussion with Communify’s Head of Product for EMEA Sam Shuff and Boring Money founder Holly Mackay – Shaping the environment: Behavioural science, engagement, and Consumer Composite Investments – to explore the question at the heart of the new regime: how do you create product information that people can actually engage with?
Introduced in April to replace the key information documents (KIDs) under PRIIPs and UCITS, the CCI conspicuously lacks any kind of template for firms to work from. “The regulator wants people to think about disclosure, they want people to think about their customer base,” Mackay told the webinar. “They want people to be able to evidence understanding, so they’re loath to provide people with a template.”
But it creates a quandary, too. “The industry hates a blank piece of paper,” Mackay said. “It makes people nervous.”
Why the FCA left the page blank
According to the FCA's own data, only around 3 percent of retail investors read their disclosures. In Boring Money's testing of retail fund investors, just 19 percent could explain what an ongoing charges figure (OCF) meant. The KID, in other words, achieved compliance without achieving understanding. “That no longer washes under Consumer Duty,” Mackay said.
The regulator's reluctance to prescribe a template is a deliberate attempt to encourage firms to start from their own customers – who they are, what they already understand, what they need to know – rather than from legal boilerplate, Shuff said. He framed the underlying design problem in terms of the US economist Richard Thaler's insight that better decisions come not from adding more information, but from changing the environment in which decisions are made.
An FCA study from 2022 tested exactly this: redesigning a fund factsheet – reordering hypothetical growth examples, changing colour coding, revising headers – lifted comprehension among 8,000 participants from 35 percent to 48 percent. “That’s one of the things that CCI is doing – forcing the industry to make that jump,” Shuff said.
That leaves firms with a fairly practical starting point. Rather than treating CCI as a document-production exercise, they can break the work down into a few questions: who is the customer and what do they need to understand; how should that information appear in the journey; and what data and evidence are needed to make the approach work?
Functional versus factual disclosure
“There’s a real difference between functional disclosure and factual disclosure,” Mackay argued. A cost disclosed as “65 basis points” is factual; it is also, to most consumers, meaningless. The functional equivalent situates that number against something a customer can actually judge – a comparative range, a peer benchmark, a real-world reference point.
She said the same logic applies to risk, which the industry still tends to communicate as either a number or a bland adjective, when the question a customer is actually asking is far blunter: “How much could I lose?”
CCI's removal of the PDF-only requirement, mandating that data be provided in computer-readable form, is what makes this shift practically possible. It is the mechanism that lets a disclosure move from a static document, embedded somewhere in a buying journey, to something that can be surfaced dynamically, at the point where a decision is actually being made, and tailored to who is making it.
There is a less visible part of this change. If product information is spread across systems, difficult to update, or tied to document-production processes, firms will struggle to make use of that flexibility. The design may sit in front of the customer, but the information feeding it still needs to be reliable, current, and accessible. Understanding the data behind the experience therefore needs to sit alongside decisions about what it looks like.
This is not merely aspirational. Communify's “Fund Story” product, which reformulates the product summary document into an interactive question-and-answer format, has been live with a Tier 1 North American bank since 2019. Shuff told the webinar that 95 percent of users who opened a Fund Story read through to the end, and those users were twice as likely to invest as users who saw only a standard fund overview.
Where responsibility actually sits
Mackay noted that Boring Money had done a lot of journey mapping and document testing with consumers. Around 35 percent of DIY investors visit a manufacturer's own website – but mainly in the early, exploratory stages of research. The later-stage work of comparison and validation – the point closest to an actual transaction – happens overwhelmingly on platforms and with wealth managers.
That doesn’t let manufacturers off the hook, but it does mean the industry needs a much clearer, and probably firm-by-firm, view of who owns which part of the customer's information experience, rather than assuming the obligation sits wherever the document happens to be hosted.
That also changes the role of testing. Consumer research should not be added at the end to demonstrate that a finished document passes muster. Firms can put an early version in front of customers, identify where confusion remains, and make changes. That improves the experience while giving compliance a clearer evidence base for judging whether it works.
None of this is comfortable for legal and compliance functions built around binary, defensible answers. “The exam question for me is, ‘would we rather our customers were perfectly wrong or approximately right?’. In the world of KIDs, people were perfectly wrong – nobody was reading them,” Mackay said.
Consumer Duty's customer understanding outcome makes that position much harder to defend, and pushes compliance teams towards a genuinely different kind of evidence: testing, done directly with target customers, showing that a defined proportion actually understood what they were told.
For firms still working out where to begin, Mackay advised starting with the questions customers have and the information they most need. Firms can then develop a template, test it with their audience and iterate, considering the data needed to support the experience alongside the design. As Shuff put it, the work falls into three areas: design, data and consumer testing – all of which require different areas of expertise.
A shift with a business case attached
Underpinning all of this is a market opportunity. UK households hold an estimated £2.2 trillion (US$2.97 trillion) in cash alongside roughly £1.1 trillion (US$1.48 trillion) in directly held investments — a combined pool of around £3.3 trillion (US$4.46 trillion). Moving even 0.5 percent of that from cash into investment represents some £17 billion (US$23 billion) in additional assets under management. Firms that can genuinely differentiate on understandability are not simply meeting a regulatory floor; they are competing for a meaningfully larger prize.
CCI therefore asks firms to move from a document designed to satisfy compliance requirements towards an experience designed around customer understanding. What that looks like will vary by firm and customer, but the work needs to start now.
The Wealth Mosaic’s webinar with Communify and Boring Money, Shaping the environment: Behavioural science, engagement, and Consumer Composite Investments, is now available to watch on demand. Click to here to watch it in full now.
About WealthTech Talks
WealthTech Talks is The Wealth Mosaic’s webinar series exploring the technology, data, regulatory, and business developments shaping the future of wealth management. Bringing together senior industry practitioners, technology specialists, and subject-matter experts, each session focuses on a specific issue facing wealth firms today, combining expert perspectives with practical insight into how new approaches can be applied in the real world.
From AI and data to digital advice, investor engagement, and regulatory change, WealthTech Talks gives participants the opportunity to understand emerging trends, learn from industry experience and consider the strategies, technologies and priorities that can help their firms respond and evolve.
Recent WealthTech Talks webinars can be viewed below:
- The agentic manager – How agentic AI is reshaping work in UK wealth management, in partnership with Profile Software
- From layered intelligence to AI in fraud defence, in partnership with LexisNexis Risk Solutions
About Communify
Communify is a leading provider of designed Financial AI, Digital, and Data solutions for global financial services in the Intelligence Era. Founded on the industry's largest Knowledge Base of integrated market and client data, Communify processes over 9 billion data requests daily for 400+ clients managing US$20 trillion-plus in AUM, serving firms across North America, Europe, and Asia-Pacific.
About Boring Money
Boring Money is an independent financial research and comparison business helping consumers make better choices about investing, saving and pensions. Its quant and qual research and insights also help financial firms understand customer needs, improve products and communicate more clearly.
About The Wealth Mosaic
The Wealth Mosaic is a UK-headquartered online solution provider directory and knowledge resource, focused specifically on the wealth management industry.
For wealth managers, the buy side of our marketplace, The Wealth Mosaic is designed to enable discovery of key solutions, solution providers and knowledge resources by specific business needs.
For solution providers and vendors, the sell side of our marketplace, The Wealth Mosaic exists to support the positioning, exposure and business development needs of these firms in a more complex and demanding market.
