This Order, made by the Treasury, amends the Consumer Composite Investments (Designated Activities) Regulations 2024, establishing temporary exemptions from the financial promotion and scheme promotion restrictions for communications related to Key Information Documents (KIDs) previously governed by the PRIIPs Regulation, effective from April 6, 2026, until December 8, 2027, within the context of the transition to the new Consumer Composite Investments regime.
Arguments For
Provides a necessary temporary exemption for financial promotions that formerly complied with the PRIIPs Regulation (Article 13) during the transition to the new Consumer Composite Investments (CCI) regime.
Ensures continuity and avoids regulatory gaps by aligning promotional activities with the FCA's transitional provisions relating to the revocation of the PRIIPs Regulation.
Establishes clear end dates for the temporary exemptions (December 8, 2028, via regulation 8A(3), overriding the CCI transitional period end date), offering regulatory certainty after the transition phase.
Arguments Against
Introduces complex, temporary legislative provisions that rely on interpreting parallel FCA rules (the FCA CCI transitional provisions), potentially increasing compliance complexity during the transition period.
Extends legal tolerance for communications that might not meet the standards of the full, post-transition CCI regime, potentially exposing consumers to less rigorously scrutinized information during the interim phase.
The exemption has a long-stop date that may not perfectly align with the operational conclusion of the entire transition, requiring future legislative certainty.
The Treasury make this Order in exercise of the powers conferred by sections 21(5) and (6), 238(6) and (7), and 428(3) of the Financial Services and Markets Act 2000.
The Treasury creates this Order using specific powers granted under sections 21, 238, and 428 of the Financial Services and Markets Act 2000 (FSMA 2000).
Citation, commencement and extent
- (1) This Order may be cited as the Consumer Composite Investments (Designated Activities) (Amendment) Order 2025 and comes into force on 6th April 2026. (2) This Order extends to England and Wales, Scotland and Northern Ireland.
The legislation is officially titled 'The Consumer Composite Investments (Designated Activities) (Amendment) Order 2025' and becomes legally active on April 6, 2026.
The rules apply across the entirety of the United Kingdom: England, Wales, Scotland, and Northern Ireland.
Amendment of the Consumer Composite Investments (Designated Activities) Regulations 2024 2. (1) The Consumer Composite Investments (Designated Activities) Regulations 2024 are amended as follows. (2) After regulation 8 (temporary exemptions), insert—
“Temporary exemptions for promotions previously subject to the PRIIPS Regulation 8A. (1) The financial promotion restriction and the scheme promotion restriction do not apply to any communication produced during the CCI transitional period where—
(a) the communication is of a kind that would have been required by Article 13 of the PRIIPs Regulation as it had effect immediately before 6th April 2026, and
(b) it complies with the requirements in the FCA CCI transitional provisions relating to that kind of communication.
(2) For the purposes of this regulation—
“the CCI transitional period” means the transitional period specified in the FCA CCI transitional provisions;
“the FCA CCI transitional provisions” means the FCA rules in DISC TP2 of the Product Disclosure Sourcebook of the FCA Handbook;
“the financial promotion restriction” means the restriction imposed by section 21(1) of FSMA 2000;
“the scheme promotion restriction” means the restriction imposed by section 238(1) of FSMA 2000.
(3) Paragraph (1) ceases to have effect on 8th December 2027.”.
This instruction amends the 2024 Regulations concerning Consumer Composite Investments (CCIs) by inserting a new Regulation 8A immediately following Regulation 8 on temporary exemptions.
New Regulation 8A exempts specific financial material from the standard financial promotion and scheme promotion restrictions if it was created during the 'CCI transitional period.' These promotions must relate to communications that would have needed compliance under Article 13 of the PRIIPs Regulation before April 6, 2026, and they must adhere to the corresponding transitional rules set out by the Financial Conduct Authority (FCA).
The exemption itself expires on December 8, 2027.