About Common Interest Investments

What We Are

CII is a for-profit company limited by shares. It provides verification, documentation, and platform services to CICs raising investment from their common interest groups under the exemptions in the Financial Services and Markets Act 2000 and the Financial Promotion Order 2005.

The platform's for-profit status is irrelevant to the exemptions because the investment offer is made by the CIC, not by CII. The communication is issued by the CIC directors, who take personal statutory responsibility under Article 52(3). CII provides the templates and verification — the same role a law firm plays, but automated and accessible.

The Problem We Solve

The cost of a fully authorised share issue for a small CIC is £20,000–£50,000. Most CICs are trying to raise £10,000–£100,000. The regulatory compliance cost alone makes most community investment uneconomic — and that's before you consider the legal fees for navigating FSMA.

The Common Interest Exemption (FPO Article 52) has existed for years, but has been almost entirely unused by CICs because:

• The legal profession has treated it as narrow (risk aversion is the product)
• The FCA has never confirmed its boundaries (no enforcement action means no clarity)
• No one has built the infrastructure to make it accessible at scale

CII changes that. We provide the infrastructure — the verification, the documentation, the platform — that makes the exemption usable by any CIC with a mission and a community behind it.

Governance

Since CII is for-profit, trust comes from governance and transparency — not legal form.

• Board — Strategy, risk, compliance oversight. At least one director with regulatory law background. At least one independent director.
• Compliance Committee — Audits all CII Verification decisions, handles appeals. Publishes quarterly compliance reports.
• Community Advisory Panel — Elected by participating CICs. Vets criteria changes, reviews complaints. Non-binding but must be answered in writing.
• Community Bonds — Two standardised pathways for bond raises. See our bond products.
• Open-Source Audit — The AI compliance engine code is public. Anyone can verify the checks.

The Vision

The Common Interest Exemption, properly read and properly implemented, is not a narrow back-alley. It is the main road for any CIC with a community mission and a list of supporters. The legal profession has been charging tolls on a road that is free to use.

CII exists to remove the tolls — to provide the infrastructure, the verification, and the assurance that makes compliant community investment accessible to every CIC.

The question is not "can Art 52 be used broadly?" — the text clearly permits it. The question is: who will be the first to test it at scale? CII is ready.

The Core Legal Argument — Article 52

CII's framework is built on Article 52 of the Financial Promotion Order 2005 (the "Common Interest Exemption"). The conventional legal view treats this exemption as narrow. CII adopts a wider reading, supported by the statutory text:

• "Existing" qualifies the interest, not the group. The interest must be in existence at the time of communication — not pre-existing the offer.
• "Common interest" can be purely mission-based. A person who supports a CIC's social mission has a genuine interest in its affairs and its use of proceeds.
• "Identified" is broader than "named." A postcode area, an affinity group, or a mailing list all satisfy the identification requirement.
• Article 52(5) — the "primary purpose" framing — aligns with and fulfills the common interest test rather than restricting it.

This applies identically whether the communication relates to shares or bonds. The Common Interest Exemption is instrument-agnostic.

Read the full analysis →

The Exemptions — How They Fit Together

Three statutory exemptions work together. All three apply to both debt and equity instruments.