The Financial Conduct Authority (FCA) has proposed three reforms to UK asset management rules that it estimates would save firms £128 million a year. New fund reporting requirements account for most of the projected benefit, although their introduction would require technology and change projects across a sector managing £16.5 trillion.
Fund Reporting for Asset Management Entities (FRAME) would replace current fund-reporting requirements with a common framework calibrated to fund type, size and activity. The FCA estimates that FRAME would reduce the aggregate reporting burden across fund managers by 75%, although the reduction would vary by firm. It calculates an equivalent annual net direct benefit of £110.98 million.The package also includes remuneration and alternative investment fund manager (AIFM) reforms. The remuneration proposals have an equivalent annual net direct benefit of £32.01 million. The AIFM proposals have an equivalent annual net direct cost of about £15.1 million, excluding flexibility benefits that the FCA could not quantify. Combined with FRAME, the three estimates produce an equivalent annual net benefit of approximately £127.9 million.
Those benefits will not be distributed evenly. Benjamin O’Connor, Principal Consultant, UK Regulatory Advisory at ACA Group, describes private-market firms at the lower end of the medium AIFM category as the “smallest winners” from the reforms.
“These private market firms … will have obligations relating to valuation, fund liquidity, and risk management that are similar to those of full-scope AIFMs today, despite not having the comparable operational complexity that more readily justifies such controls,” he says.
Larger medium AIFMs operate with greater complexity and should be better placed to accommodate the requirements, according to O’Connor.
FRAME would divide reporting into essential and enhanced requirements. Most AIFs and UK UCITS below £500 million NAV would provide essential reporting, while those at or above that threshold would add enhanced information. Some populations, including recognised overseas schemes, would remain subject only to essential reporting.Hedge funds and authorised funds would generally report quarterly. Other fund types would report annually. Enhanced requirements include fund strategy, investor base, fees, flows, portfolio concentration, liquidity, borrowing, counterparty exposure and private-market risks. Larger hedge funds would face event-based reporting.
Detailed reporting would be concentrated on larger funds and activities the FCA considers more likely to affect consumers or market integrity. The reduction in reporting effort will vary by firm.
FRAME would introduce regular holdings reporting for UK Undertakings for Collective Investment in Transferable Securities (UCITS) and non-UCITS retail schemes with NAV of at least £500 million. Except for money market funds, the FCA does not currently receive regular holdings reports. The data would give supervisors a direct view of portfolio composition and help them assess consistency with a fund’s objectives, strategy, liquidity and risk profile.
Other proposed FRAME data serves broader supervisory purposes. The FCA says improved fund reporting could help it identify inaccurate valuations, poor-value products, liquidity problems and retail clients wrongly categorised as professional clients. It also wants to spot funds with poor performance, consumer risk or systemic risk sooner.
FRAME takes account of transaction and post-trade data available under UK MiFIR, EMIR and SFTR. The FCA also proposes consistent use of Legal Entity Identifiers for funds, managers, depositaries and delegates, allowing supervisors to connect fund reports with data collected under those regimes.
The FRAME cost-benefit analysis estimates £139.8 million in one-off implementation costs: £74.5 million for technology projects, £58.2 million for change programmes and £7 million for familiarisation and gap analysis. Firms are therefore likely to map the new fields to source systems, amend reporting controls and test submissions before the final requirements take effect.
The distribution of recurring costs and benefits varies by fund type. Alternative investment funds would receive an estimated £147.8 million in annual net benefits. UCITS funds would incur £19.6 million in new annual costs because no comparable standardised fund-level reporting baseline currently exists.
Current Annex IV submissions show the reporting mix: 40% of firms rely solely on Extensible Markup Language (XML) uploads, 35% use an online form and 24% use both. The consultation proposes retaining XML and online forms for all reporters. It also asks whether enhanced reporters should use XML alone because their submissions will be more complex and detailed. The consultation discusses online forms and XML uploads but does not identify an application programming interface submission option.
The wider reforms would introduce a three-tier AIFM regime and consolidate most AIFM requirements in one sourcebook. A single outcomes-focused remuneration code would replace three overlapping codes.
The remuneration consultation closes on 16 September 2026. Responses to most AIFM discussion chapters are due on 18 September, followed by FRAME on 22 September and the main AIFM consultation on 14 October. The FCA plans further FRAME prototypes before the end of 2026 and final rules in the first half of 2027, with full implementation targeted for 2028.
The projected savings depend on how far reduced reporting effort converts into lower costs. The FCA’s sensitivity analysis tests lower effort reductions and cost-realisation rates, leaving the £110.98 million FRAME estimate subject to consultation feedback and firms’ experience of the prototypes.
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