The purpose of the paper? Cut through years of overlapping MiFID, IDD and non-MiFID rules, and align cost disclosures with the new Consumer Composite Investments (CCI) regime.

The direction is clear: simpler, more consistent, more engaging disclosures that help consumers understand what they're paying and why.

In other words, the regulator wants firms to bring Consumer Duty thinking into every corner of their cost disclosures, not just tick a compliance box.

We've taken a deep dive into the paper! So here's what the FCA's proposal to simplify investment disclosures (CP26/24) means for firms, and what to do next. ‍

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What does CP26/24 cover?

The proposals focus on bringing together the current patchwork of cost disclosure rules and giving firms one clear, consistent framework to follow. ‍

The consultation proposes:

• Combining MiFID, IDD and non-MiFID cost disclosure rules into a single new chapter of the FCA Handbook (COBS 6A)

• Aligning pre-sale cost presentation with the CCI product summary approach, showing ongoing product and service costs together, with one-off costs, transaction costs and performance fees disclosed separately

• Removing the pre-sale cumulative effect illustration altogether, and reworking the post-sale version so it shows the real impact of costs on performance

• New rules on cash holdings, banning firms from charging fees on cash while also keeping the interest earned on it ("double-dipping"), and requiring clear upfront disclosure of interest rates and fees

• Reduced prescription for disclosures to professional clients and eligible counterparties, giving firms more flexibility to agree bespoke arrangements

The FCA is consulting on these proposals until 21 August 2026, with a Policy Statement expected by the end of 2026. Implementation will be phased, with the new cash interest disclosure rules coming into force from June 2027, and the wider COBS 6A changes following an 18-month transition period to around June 2028. ‍

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What do advice firms need to do?

Throughout the paper, the message is clear: firms should get ahead of these changes now, rather than waiting for the final rules to land.

Firms should start by reviewing their current pre- and post-sale cost disclosure documents and templates against the proposed COBS 6A structure, checking that their systems and data can separate out one-off costs, transaction costs, performance fees and CEIF costs rather than lumping them together.

Firms should also look closely at their cash holding practices, ensuring they aren't both charging a fee and retaining interest, and start preparing clear, consumer-friendly explanations of how they set their rates.

‍In short, actions for firms on the back of CP26/24:

• Audit current disclosure documents and templates against the proposed COBS 6A framework

• Check systems and data capability for separating out cost categories rather than aggregating them

• Review cash holding practices and confirm there's no double-dipping on fees and interest

• Flag any disclosure processes still split across old MiFID, IDD and non-MiFID lines that will need consolidating

• Consider responding to the consultation by 21 August 2026 if the proposals affect your business model

In practice, this could mean firms redesigning documents and rethinking how cost information is built into the customer journey from the outset, rather than bolted on as a static PDF. ‍

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Key takeaways

The regulator's main emphasis is on clarity, consistency and real consumer understanding, moving away from rigid templates and towards disclosures that firms can tailor in line with their Consumer Duty responsibilities.

Firms that treat this as a "wait and see" exercise risk a rushed scramble once the Policy Statement lands. If you start reviewing data, systems and cash disclosures now you will be far better placed to implement smoothly and avoid unnecessary cost. ‍

Need a hand?

As always, our expert compliance team are here to help.  

If you have questions about how the FCA's proposals on investment disclosures may affect your firm, or need guidance preparing your systems, documents and disclosures ahead of the changes, book a call now.

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