The UK’s move from Priips to the more flexible CCI regime does not reduce complexity but shifts it from regulatory templates to underlying data quality and governance.
For years, Priips has been one of the most hotly debated pieces of financial regulation in Europe. Designed to help retail investors better understand investment products, many have argued that it often did the opposite. Standardised templates produced results that were technically compliant but, in many cases, confusing or even misleading.
Firms operating across both the UK and Europe will need to support CCI alongside Priips for the foreseeable future - Yann Bloch
Now the UK is taking a different path. With the introduction of Consumer Composite Investments, or CCI, the UK is moving away from the current Priips framework towards something more flexible. In theory, it will be welcome. Firms will have more freedom to present information in a way that genuinely helps investors understand risk, cost and performance. But that flexibility comes with a trade-off. What looks simpler on the surface may become more complex in practice.
Under Priips, the rules were prescriptive. Firms knew exactly what to produce and how to present it. That created its own problems, but it also meant compliance was relatively straightforward to verify. With CCI, that clarity is reduced. Firms will have greater discretion over how disclosures are structured, written and delivered.
That raises an important question. If everyone can present information differently, how do you ensure consistency, comparability and compliance? The answer lies not in the format of the report, but in the quality of the data behind it.
As reporting becomes less standardised, the burden shifts upstream. Firms will need stronger data governance, clearer processes and tighter controls to ensure that what they produce is accurate and defensible. It will no longer be enough to follow a template. Firms will need to demonstrate that their disclosures are built on robust, well-managed data.
This is where many organisations may find themselves underprepared. Across the industry, it is still common to see fragmented reporting architectures. Different teams use different tools for different regulations. Data is duplicated, transformed and reconciled multiple times across systems. That approach was already inefficient under Priips. Under CCI, it risks becoming unworkable. The temptation may be to treat CCI as a standalone problem and build a new solution around it. That would be a mistake.
Firms operating across both the UK and Europe will need to support CCI alongside Priips for the foreseeable future. Creating separate, siloed processes for each regime will increase operational risk, drive up costs and make consistency harder to achieve.
A more sustainable approach is to invest in a unified data foundation that can support multiple regulatory outputs. That means centralising data management, standardising definitions and ensuring that reporting draws from a single, controlled source of truth. In this context, flexibility becomes manageable. Without it, flexibility becomes a liability.
There is also a broader shift taking place. As regulatory frameworks become less prescriptive, the responsibility for interpretation moves from regulators to firms. That increases the importance of internal governance and oversight. It also raises the stakes when things go wrong.
None of this means that the move away from Priips is misguided. On the contrary, the intention behind CCI is sound. Giving firms more freedom to communicate clearly with investors is a step in the right direction. But it would be naïve to assume that fewer rules automatically mean less complexity. In reality, the complexity has not disappeared. It has simply moved.
Firms that recognise this early and invest in the right data, governance and operating models will be well placed to adapt. Those that rely on quick fixes or fragmented solutions may find that a more flexible regime is also a more demanding one. The UK has opened the door to better disclosures. The challenge now is making sure the industry can walk through it without losing control of the information that matters most
Disclaimer: the views, information or opinions expressed herein are those of Yann Bloch, and do not necessarily reflect the views of SRP.
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