With mandatory adoption of the FCA’s Consumer Composite Investments regime set for 8 June 2027, product manufacturers are now working through what the new CCI product summary data requirements mean in practice.
For many firms, the main challenge will not be the final document output. It will be the data required to produce it accurately, consistently and at scale.
Some firms are already progressing implementation. Others are still assessing the operational impact. Wherever you are in that process, one issue is becoming increasingly clear across CCI readiness projects: data sourcing is where implementations are most likely to slow down, or stall entirely.
The reality is that CCI is not simply a documentation exercise. It is a data architecture, sourcing and validation challenge.
Product manufacturers that identify their data requirements early will be better placed to protect project timelines, avoid late-stage remediation, and transition to CCI Product Summaries with greater confidence.
What Are the CCI Product Summary Data Requirements?
At a high level, firms need to source, validate and maintain data across several key areas to support CCI Product Summary production.
These include:
- 10 years of historic price and dividend data to support Risk and Reward Score calculations.
- Monthly performance data, including benchmark returns, for the Growth of £10k graph.
- Underlying cost data for closed-ended fund holdings.
- Explicit transaction cost data, which may need to be sourced from systems beyond administrator trade files.
Each of these areas introduces operational complexity. In many cases, the required data may not be held in one place, may not be available in the required format, or may not have been collected historically because it was not needed under previous regimes.
That is why firms should treat CCI data sourcing as an early-stage implementation workstream, not a clean-up task to address once document production begins.
CCI Product Summary Data Requirements: Where Firms Struggle Most
Based on our experience supporting fund document and regulatory reporting implementations, four areas commonly require early attention.
1. Historic Data Requirements for CCI Product Summaries
One of the most important CCI product summary data requirements is the need for 10 years of historic data to support the new Risk and Reward Score methodology. This represents a significant expansion compared with the previous SRRI approach, which used five years of data.
For many product manufacturers, this will create immediate practical challenges.
Historic prices, dividends and synthetic data may not be held centrally. In some cases, funds may have changed ACD, administrator or operating model over the past decade. Where that has happened, data may be split across multiple providers, legacy systems or archived records.
The challenge becomes more acute where historical data was not required previously, was not retained in a usable format, or needs to be reconstructed from external sources.
Firms should therefore begin by asking:
- Do we have a complete 10-year data history for each product?
- Has the fund changed administrator, ACD or data provider during that period?
- Are there gaps in historic prices, dividends or synthetic data?
- Can missing data be sourced externally if required?
- Is the data available in a format that can be ingested, validated and used for calculation?
In our experience, this is one of the hardest issues to resolve at short notice. Identifying gaps early is critical.
2. Monthly Performance Data Requirements for Growth Calculations
CCI Product Summaries also require monthly performance data to support the Growth of £10k graph. Product manufacturers need to determine how they will calculate monthly performance returns, including benchmark returns where applicable.
There are broadly two approaches.
The first is to calculate monthly performance from the raw data already captured for Risk and Reward Score calculations. The second is to extract monthly performance figures from historic factsheets or other published materials.
Both options can work, but neither should be underestimated.
Calculating from raw data may provide greater consistency, but it depends on the availability and quality of the underlying data. Extracting figures from factsheets may appear simpler, but historical factsheets can vary by format, methodology, source and availability.
Questions firms should consider include:
- Is monthly performance data already available for all relevant products?
- Are benchmark returns available for the same periods?
- Are historical factsheets complete and accessible?
- Is the data consistent across share classes, funds and reporting periods?
- Can the calculation methodology be applied consistently across the product range?
This is a good example of where CCI data requirements can look straightforward at first glance but become more complex during implementation.
3. Closed-Ended Fund Cost Data Requirements
The treatment of underlying costs for closed-ended funds is a further area that can create significant practical difficulty.
This is a new calculation for CCI and can be challenging on two fronts.
First, firms need to identify which holdings are closed-ended products. Ideally, this should be done in as automated a way as possible. However, this depends on whether administrator portfolio master files or internal systems clearly flag the relevant instruments.
Second, firms need to source the ongoing costs of those products. This can be difficult because many of these costs are not publicly available and may require direct outreach to the underlying funds or product providers.
This can quickly become a time-consuming exercise, particularly for managers with broad portfolios, complex fund-of-fund structures or exposure to multiple closed-ended vehicles.
Key questions include:
- Can closed-ended fund holdings be identified reliably from current data sources?
- Does the portfolio master file include sufficient classification data?
- Are ongoing cost figures publicly available?
- If not, who is responsible for contacting the underlying funds?
- How will responses be tracked, validated and refreshed over time?
This is one of the clearest examples of why CCI product summary data requirements need to be assessed early. Waiting until the production phase may leave insufficient time to gather, validate and apply the required cost data.
4. Explicit Transaction Cost Data Requirements
Explicit transaction costs may also present challenges, particularly where the required data is not captured in the trade files that flow to administrators.
In many cases, product manufacturers may need to look beyond administrator data and source information from Order Management Systems or other internal platforms. This can introduce integration, completeness and data quality issues.
The challenge can be particularly pronounced for pooled products, where transaction cost data may not be readily available in the structure or granularity required for CCI Product Summary production.
Firms should assess:
- Where explicit transaction costs are currently captured.
- Whether administrator trade files include all required fields.
- Whether OMS or other internal systems need to be integrated.
- How data quality will be checked before calculation.
- Who owns remediation where data is missing or incomplete.
As with other CCI data challenges, the issue is not only whether the data exists. It is whether it can be accessed, standardised, validated and used consistently within the production process.
Why Early Data Readiness Matters for CCI Implementation
Data sourcing is often the largest cause of delay in fund document production projects. That has been true across UCITS KIID and PRIIPs KID implementations, and it is likely to be just as important for CCI Product Summaries.
The difference with CCI is the scale and depth of the data required.
Product manufacturers need to move from high-level regulatory interpretation into practical operational planning. That means identifying required data inputs, confirming ownership, mapping sources, validating formats and resolving gaps well ahead of production deadlines.
Seamus O’Cuill, Head of Fund Document Solutions at Funds-Axis, explains:
“From our experience of client implementations, difficulty in sourcing data tends to be the biggest cause of delay in any UCITS KIID, PRIIPs KID, or CCI Product Summary project. Product manufacturers need to be across the data requirements from the outset, whether they are outsourcing production or handling it internally. The additional data demands of CCI compared to what came before should not be underestimated, and gaps that surface late in a project can derail launch timelines entirely.”
That is the key point for firms preparing for CCI: the earlier data issues are found, the easier they are to solve.
Once the Data Is in Place, Galaxy Handles the Rest
Once your CCI product summary data requirements are defined and the necessary inputs are available, Funds-Axis is well placed to support the full production workflow.
Galaxy has established connectivity with a large number of fund administrators, and our Enterprise Data Management team has extensive experience ingesting data from multiple sources and in multiple formats.
From there, Galaxy supports the end-to-end CCI Product Summary process, including:
- Data ingestion and validation.
- Risk and Reward Score calculations.
- Cost calculations.
- Product Summary Document generation.
- Digital product summary outputs.
- Machine-readable datasets.
- Ongoing operational oversight.
This gives firms a scalable, controlled and repeatable approach to CCI implementation, reducing manual effort and helping to manage the operational complexity created by the new regime.
Preparing for CCI Product Summary Data Requirements
For firms preparing for CCI, the priority should be to begin the data assessment as early as possible.
A practical readiness exercise should include:
- Mapping all required CCI data inputs.
- Identifying internal and external data sources.
- Assessing gaps across historic prices, dividends and performance data.
- Reviewing availability of closed-ended fund cost data.
- Confirming where explicit transaction costs are held.
- Testing data ingestion and validation processes.
- Agreeing ownership for unresolved data issues.
The firms that move early will be better positioned to manage the transition efficiently. Those that leave data sourcing too late risk putting their implementation timeline under unnecessary pressure.
CCI Product Summary production may ultimately result in a document, but the success of the project depends on the quality, completeness and availability of the data behind it.
FAQs: CCI Product Summary Data Requirements
What data is required for a CCI Product Summary?
CCI Product Summary production requires data across several areas, including historic price and dividend data, synthetic data where required, monthly performance data, benchmark returns, underlying cost data for closed-ended fund holdings, and explicit transaction cost data.
How far back does historic data need to go for CCI?
The new Risk and Reward Score requires 10 years of historic data, compared with the five-year period used under the previous SRRI methodology. This means firms may need to source older records from administrators, previous providers or external data sources.
What is the biggest challenge with CCI product summary data requirements?
The biggest challenge is often sourcing complete, accurate and usable data from multiple systems, providers and historical records. Data gaps discovered late in the project can delay implementation and create additional remediation work.
Why are closed-ended fund costs difficult to source under CCI?
Closed-ended fund cost data can be difficult because firms first need to identify which holdings are closed-ended products, then source ongoing cost figures. In many cases, this information may not be publicly available and may require direct outreach to the underlying funds.
Can CCI Product Summary production be outsourced?
Yes. Firms can outsource elements of CCI Product Summary production, including data ingestion, calculations, document generation and digital outputs. However, product manufacturers still need to understand their data requirements and ensure the necessary inputs can be sourced and validated.
See Galaxy in Action
If you would like to see how Galaxy handles CCI end to end, or want to talk through your data readiness ahead of implementation, we are happy to help.
