The Bottom Line
- Marketing Continuity: Firms can continue to use existing marketing documents (formerly PRIIPs Key Information Documents) for ‘Consumer Composite Investments’ without breaching financial promotion rules after the old regime ends.
- A Clear Timeline: This temporary exemption provides a crucial transition period from 6th April 2026 until 8th December 2027, allowing for an orderly shift to the new UK-specific disclosure regime.
- Action Required: This is a temporary safe harbour, not a permanent solution. Compliance and marketing teams must use this period to prepare new disclosure documents that align with the FCA’s full CCI regime before the 2027 deadline.
The Details
The UK Treasury has introduced this Order to manage a critical transition in financial services regulation. From 6th April 2026, the UK will officially revoke the retained EU law known as the PRIIPs Regulation, which governs pre-contractual information for packaged retail and insurance-based investment products. This change is part of a broader move to a new, UK-specific framework for Consumer Composite Investments (CCIs). Without this intervention, any existing documents like Key Information Documents (KIDs) could have instantly become illegal financial promotions under the Financial Services and Markets Act 2000 (FSMA), creating a disruptive “cliff-edge” for the industry.
This Amendment Order provides a direct and practical solution. It inserts a new temporary exemption (Regulation 8A) into the primary CCI Regulations. This new rule creates a legal safe harbour, stating that communications like KIDs will not fall foul of the UK’s strict financial and scheme promotion restrictions during the transitional period. For the exemption to apply, the communication must be of a kind that was previously required under the old PRIIPs rules and must also comply with the new transitional provisions laid out by the Financial Conduct Authority (FCA) in its Handbook.
For CEOs and legal counsel, the message is one of managed change. This Order provides welcome operational stability and prevents the immediate need to withdraw or overhaul vast quantities of product literature on 6th April 2026. However, the clock is ticking. The exemption is explicitly temporary, expiring on 8th December 2027. Businesses must use this window to strategically plan, budget for, and implement the necessary changes to their disclosure documents and marketing processes to ensure full compliance with the new, permanent CCI regime once this grace period ends.
Source
UK Statutory Instruments
