On 14 July 2026, the Financial Conduct Authority (FCA) published two linked consultation papers. CP26/28 proposes reforms to the UK Alternative Investment Fund Managers (AIFM) regime, including the removal of AIFMD Annex IV reporting, while CP26/26 introduces Fund Reporting for Asset Management Entities (FRAME), a new reporting framework covering AIFs, UK UCITS and other fund types. Together, the proposals set the UK on a distinct path from the EU’s evolving fund reporting framework.

Who will report under FRAME?

FRAME applies to FCA-authorised UK AIFMs (covering the AIFs they manage), managers of Registered Venture Capital Funds (RVECA) and Social Entrepreneurship Funds (SEF), UK UCITS, third-country AIFs marketed under the National Private Placement Regime (NPPR), and overseas funds recognised under the Overseas Funds Regime (OFR) or individually under section 272 FSMA.

The FCA estimates that FRAME encompasses almost 32,000 active funds managed and/or marketed in the UK. The largest category is around 12,000 AIFs marketed under the NPPR, followed by 8,400 unauthorised AIFs managed in the UK, nearly 7,900 overseas UCITS recognised under the OFR and 2,500 UK UCITS. By comparison, authorised AIFs such as Non-UCITS Retail Schemes (NURS), QIS and LTAFs together account for only a small proportion of the total population.

Essential and enhanced reporting

FRAME calibrates reporting along two dimensions. A £500 million NAV threshold at the level of the individual fund separates an “essential” dataset from an “enhanced” one, while reporting frequency and content are further tailored to the liquidity and characteristics of different fund types.

The essential dataset focuses on core information about the fund, including its profile and investment strategy, investor base, performance, flows and liquidity. The enhanced dataset builds on this foundation with substantially more granular information, including detailed data on holdings, portfolio exposures, market risk, counterparties and financing, together with specialised modules for private markets, private equity and loan origination funds where relevant. Not every fund is required to complete every section of either the essential or enhanced dataset; the applicable reporting modules depend on the fund type and other relevant characteristics.

Practical considerations

The industry impact may be broader than it first appears

The FCA estimates that only around 9% of funds would be required to submit the enhanced dataset. While this demonstrates the regulator's intention to apply the most granular reporting requirements proportionately, the implementation effort across the industry may be considerably larger.

Reporting solutions are typically designed and operated at manager level rather than on a fund-by-fund basis. Firms rarely build separate reporting infrastructure for a single fund; instead, they implement common data models, validation rules and reporting processes across their product range. As a result, the proportion of funds above the £500 million threshold may underestimate the implementation effort across the industry. Instead, a more useful consideration is the proportion of managers with at least one enhanced-reporting fund, together with funds that are likely to exceed the threshold as assets under management grow. The market-wide implementation effort could therefore be significantly greater than the headline 9% figure suggests.

Regulatory divergence requires a common data foundation

For firms operating across both the UK and the EU, the replacement of Annex IV with FRAME creates a clear divergence in regulatory reporting. Under the previous framework, many firms could leverage a common Annex IV reporting capability across jurisdictions. Going forward, UK and EU reporting will follow different regulatory frameworks, increasing operational complexity for UK managers marketing funds into the EU and EU managers accessing the UK market.

This divergence also makes the FCA's projected reduction in reporting costs more difficult to assess. Even if FRAME simplifies reporting within the UK, firms with cross-border activities will still need to meet EU reporting obligations under AIFMD II / UCITS VI alongside FRAME, limiting the extent to which existing reporting processes and reports can be decommissioned.

This further reinforces the importance of establishing a common regulatory data model that clearly distinguishes reusable data from jurisdiction-specific reporting requirements. While the reporting templates will differ, much of the underlying portfolio, reference and risk data can be sourced, governed and validated consistently across multiple regulations.

From this perspective, we welcome the FCA's decision to build on the existing AIFMD asset classification. As the FCA notes, it has "used existing AIFMD categories where possible and supplemented them where further detail would improve supervisory understanding" — extending the established taxonomy through additional sub-asset classes rather than introducing an entirely new one. Retaining the AIFMD baseline should make it easier for firms to reuse underlying data across UK and EU reporting and avoid maintaining a parallel classification scheme solely for UK purposes.

Holdings data: a step towards reusable regulatory data

One of the most significant enhancements under FRAME is the introduction of instrument-level holdings data for UK UCITS and NURS. We welcome this direction, which aligns with the broader move towards more granular portfolio reporting in Europe under AIFMD II and the expected evolution of UCITS reporting.

High-quality, validated holdings data identified at ISIN level should become a reusable regulatory data asset across multiple reporting frameworks. This is particularly relevant for securities funds, where consistent holdings data can support different regulatory reporting obligations without requiring multiple representations of the same portfolio.

This also aligns with the broader move towards integrated regulatory data collection in the EU, where standardised holdings data can be reused across multiple supervisory frameworks rather than prepared separately for each reporting obligation. We discussed this topic in more detail in our articles on ESMA’s proposed integrated fund reporting framework and EIOPA’s discussion paper on integrated data collection, including the potential for regulatory data to be reused across the fund and insurance sectors.

One area that may nevertheless remain challenging is the reporting of holdings at fund rather than share class level. This may not fully capture certain share class-specific exposures, such as FX hedging derivatives. This may become particularly relevant where firms seek to reuse holdings data across multiple regulatory reporting frameworks that require share class-level transparency or risk calculations, for example Solvency II fund look-through reporting.

Coordinating implementation timelines

Although FRAME is expected to be implemented in 2028 (and the EU's integrated collection around 2029), both the FCA's final Policy Statement and the EU's technical standards are expected around the first half of 2027. The effective window for key data-model and architecture decisions is therefore 2027 — earlier than the headline implementation dates imply — which is another reason to plan the two regimes together rather than sequentially.

Key milestones

  • 14 July 2026 – The FCA publishes CP26/26 (FRAME) and CP26/28 (AIFM regime reform).
  • 22 September 2026 – FRAME consultation (CP26/26) closes. (The linked AIFM regime consultation, CP26/28, runs later and closes 14 October 2026.)
  • Before the end of 2026 – The FCA plans to publish additional prototype reporting forms for industry testing.
  • First half of 2027 – Final Policy Statement and rules are expected.
  • 2028 – Full implementation of FRAME is targeted, although the FCA is exploring whether some aspects of reporting could be introduced earlier, depending on firms’ readiness.

How can asset managers prepare?

Although the final rules are still subject to consultation, firms can already begin preparing for the transition.

  • Assess your scope. Identify which entities and funds fall within FRAME, and determine which funds are likely to require the enhanced dataset based on the proposed £500 million NAV threshold.
  • Review your data architecture. Compare the proposed FRAME datasets with your existing reporting capabilities, including AIFMD Annex IV, FCA reporting and internal data models, to identify new data requirements, opportunities to reuse data across UK and EU reporting, and any jurisdiction-specific extensions that may be required.
  • Participate in FCA testing. The FCA intends to publish additional prototype reporting forms before the end of 2026. Testing these early can help identify implementation challenges and inform your consultation response.
  • Consider responding to the consultation. The FRAME consultation remains open until 22 September 2026, providing an opportunity to comment on proportionality, reporting requirements, implementation timelines and other practical aspects of the proposed framework.
  • Start implementation planning. While full implementation is targeted for 2028, key decisions on data architecture, operating models and reporting platforms are likely to be made during 2027, particularly for firms implementing FRAME alongside AIFMD II or future UCITS reporting reforms.

Looking ahead

In our view, the FCA's final Policy Statement, together with the RTS and ITS under AIFMD II and the future UCITS VI reporting framework, will be important milestones in the evolution of regulatory fund reporting. Together, these initiatives point towards increasingly granular and standardised supervisory data, creating greater opportunities to reuse underlying data across multiple regulatory objectives.

For firms, this reinforces the importance of investing in robust underlying data foundations that can support evolving regulatory requirements over the coming years.

If you would like to discuss how FRAME, AIFMD II or UCITS VI may affect your reporting framework, data architecture or implementation plans, please get in touch with our team.

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