By Bradley Stratford, Principal Consultant
At a glance
Understanding the FCA’s FRAME proposal
On 14 July 2026, the FCA published consultation paper CP26/26: Fund Reporting for Asset Management Entities (FRAME). The proposal is designed to simplify and modernise how asset managers report information about the assets (including funds) they manage. consultation closes on 22 September 2026, with the FCA aiming for implementation during 2028. It’s important to note that the FRAME proposals remain subject to consultation and may change before being finalised rules are published.
Today, fund managers are subject to a range of different reporting requirements depending on the type of fund they operate. The FCA believes this has created inconsistent data, duplicated reporting and unnecessary complexity. FRAME is designed to create a single, more consistent reporting framework across the whole asset management sector.
The FCA’s key objectives are to:
- Replace multiple existing fund reporting returns with consolidated reporting forms
- Improve the quality and consistency of information received by the regulator
- Reduce some existing notification requirements
- Introduce a more proportionate reporting regime for smaller firms and funds
What does this mean for asset management firms in the UK?
Simpler reporting requirements
- Many firms currently submit different reports across different regulatory regimes. FRAME is intended to bring these together into a more streamlined structure, reducing duplication and making reporting more efficient and less time consuming
More in-depth reporting obligations for larger asset managers
- The FCA is proposing a risk-based approach. Firms managing larger funds, or funds that could have a greater impact on consumers or markets, would be expected to provide more detailed information than smaller firms
Lighter requirements for smaller fund managers
- A positive aspect of the consultation is the FCA’s focus on proportionality. Smaller firms and smaller funds would generally face fewer reporting requirements, helping reduce regulatory burden where the FCA considers the underlying risk to be lower
Greater focus on fund risk and investor protection
- The FCA wants better data to help identify areas such as liquidity concerns, poor-value products, inaccurate valuations and potential consumer harm. This reflects a broader regulatory trend towards earlier risk identification and more data-driven supervision
Who could be impacted by the proposed changes?
The proposals are relevant to a wide range of firms including:
- UK alternative investment fund managers (AIFMs)
- UK UCITS management companies
- Venture capital and social entrepreneurship fund managers
- Overseas managers marketing funds into the UK under the National Private Placement Regime (NPPR)
- Operators of recognised overseas funds
- Certain MiFID investment managers and advisers
- Operators of collective investment schemes
Service providers such as administrators, compliance providers and depositaries may also be indirectly affected as firms review their data collection and reporting processes.
Practical impacts of the FRAME regime – and what to address first
We recommend firms to consider the likely impacts of FRAME in their short-, medium- and long-term planning:
Short term
- Firms should review the consultation and assess whether their current reporting processes would support the proposed framework
- Firms should review their fund reporting data sources to understand any gaps between the data they currently report compared to the post-FRAME implementation data requirements
- Trade bodies and industry participants may wish to submit feedback before the September deadline
Medium term
- Managers may need to enhance data gathering, governance and reporting systems
- Firms with multiple fund structures could benefit from a more standardised reporting approach
Long term
- Regulatory reporting should become more consistent and easier to manage across different fund types
- The FCA is likely to gain better insight into market risks, resulting in more targeted supervision of the sector
The key takeaway for firms
The FCA is not introducing a new prudential burden on funds, but rather redesigning how information is reported. Most firms should view FRAME as a data and reporting transformation initiative, rather than a change to investment strategy or fund operations. While larger managers are likely to see increased reporting expectations, many smaller firms could ultimately benefit from a simpler and more proportionate framework.
How IQ-EQ can help
We support numerous clients with submission of their existing Annex IV reporting obligations (AIF1 and 2 returns), whether the funds are distributed in the UK or into the EU via domestic NPPRs.
For all managers distributing funds into the UK, as the FCA progresses its proposed reforms, our experienced compliance specialists can help firms assess the potential impact of FRAME on their reporting obligations post-implementation.
If you’d like to learn more about our UK compliance consulting services and support for FCA-regulated firms, please contact our team today.
We’ll be monitoring progress on the proposed changes under CP26/26 and will publish an update following release of the proposed Policy Statement during the first half of 2027.
About the author
Bradley Stratford is a Principal Consultant in our UK compliance consultancy team, with 25 years’ experience in asset management, private wealth and family office compliance.
