CCI Product Summary: Data Sourcing Challenges and How to Prepare

CCI Product Summary Data Requirements: The Data Sourcing Challenges You Need to Solve Early

With mandatory adoption of the FCA’s Consumer Composite Investments regime set for 8 June 2027, product manufacturers are working through what the CCI Product Summary data requirements actually mean in practice. Some firms are mid-implementation. Others are still assessing their approach. Wherever you are in that process, one thing we are seeing consistently across our CCI implementations is that data sourcing is where projects slow down, or stall entirely.

Getting ahead of it early is the single most effective thing a product manufacturer can do to protect their timeline.

Here is a breakdown of the four areas that most commonly require attention.

Historic prices, dividends, and synthetic data

The new Risk and Reward Score (RRS) requires 10 years of historic data, compared to 5 years under the previous SRRI methodology. For many funds, particularly those that have changed ACD or administrator, sometimes more than once, in the past decade, that data may not be held centrally or may not have been required before. Identifying gaps early and establishing a plan to source missing records externally is essential. In our experience, this is one of the harder problems to solve at short notice.

Monthly performance data

Product manufacturers need to decide how they will calculate monthly performance returns, including benchmark returns, for the Growth of £10k graph. There are broadly two approaches: calculating from raw data captured for the RRS, or extracting monthly figures from the last 10 years of factsheets. Either way, the data collection exercise is more involved than it might initially appear, and the right approach will depend on what data is already available and in what format.

Underlying costs of closed-ended funds

This is a new calculation for CCI and the data requirements can be challenging on two fronts. First, identifying which holdings are closed-ended products in as automated a way as possible, whether or not the administrator’s portfolio master file flags this. Second, sourcing the ongoing costs of those products. Many are not publicly available, which means reaching out directly to the funds concerned. This can be a time-consuming process and is best started early.

Explicit costs

Explicit transaction costs may not be captured in the trade files that flow to administrators. In many cases, product manufacturers need to look to Order Management Systems or other sources, which can present its own integration and data quality challenges, particularly for pooled products.

Seamus O’Cuill, Head of Fund Document Solutions at Funds-Axis, puts it plainly:

“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.”

Once the data is in place, Galaxy handles the rest

The good news is that once your data sourcing strategy is confirmed and the inputs are available, Funds-Axis is well placed to take it from there. 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 automates the full CCI production workflow, RRS and cost calculations, Product Summary Document generation, digital product summary outputs, and machine-readable datasets, all from a single platform.