The FCA has published CP26/26, Fund Reporting for Asset Management Entities (FRAME), setting out proposals to replace the current collection of fund reporting requirements with a single, more consistent reporting framework. The proposals form part of the FCA’s wider programme to modernise the UK asset management regime, improve the quality of regulatory data and reduce unnecessary reporting complexity for firms. The consultation closes on 22 September 2026, with the FCA aiming to publish final rules during 2027 and implement the new regime in 2028.
Why is the FCA making these changes?
Over time, fund managers have become subject to a growing number of regulatory reporting requirements, many of which have developed independently of one another. As a result, firms often submit similar information through different forms, using different reporting formats and methodologies. The FCA believes this approach creates unnecessary operational burden for firms whilst making it more difficult for the regulator to analyse information consistently across the sector. FRAME is intended to provide a more streamlined reporting regime that delivers higher-quality data without imposing unnecessary duplication.
What is FRAME?
FRAME (Fund Reporting for Asset Management Entities) is a proposed reporting framework that would consolidate a number of existing regulatory returns into a single reporting regime. Rather than requiring firms to complete multiple reporting forms depending on the type of fund they manage, the FCA proposes a common reporting structure which is calibrated according to:
- the type of fund;
- the firm’s activities;
- the size of the assets managed; and
- the potential risks presented by the fund.
This should result in firms providing more consistent information, whilst ensuring reporting remains proportionate to the scale and complexity of their business.
What information will firms report?
A key feature of FRAME is the introduction of two reporting tiers: Essential Reporting and Enhanced Reporting.
Funds with a net asset value (NAV) below £500 million will generally be subject to Essential Reporting, which provides the FCA with a baseline dataset covering areas such as:
- fund characteristics and structure;
- assets under management;
- investment strategy;
- investor types and concentration;
- basic liquidity and leverage information; and
- other key information needed for the FCA’s ongoing supervision.
Funds with a NAV of £500 million or more will generally be required to submit Enhanced Reporting. This builds upon the essential dataset by requiring more detailed information, including:
- detailed liquidity profiles and redemption arrangements;
- leverage calculations and financing arrangements;
- derivatives exposures and counterparty concentrations;
- portfolio composition and asset-level information (where applicable);
- stress testing and risk metrics; and
- other supervisory data enabling the FCA to monitor systemic and market risks more effectively.
Importantly, the £500 million threshold applies on a fund-by-fund basis, rather than at manager level. As a result, a firm managing multiple funds may be required to submit both Essential and Enhanced reports depending on the size of each individual fund.
A more proportionate approach
A central objective of FRAME is to create a more proportionate reporting regime. Rather than requiring all firms to submit the same level of information, reporting requirements will be tailored according to the size and risk profile of individual funds.
The introduction of the £500 million NAV threshold is intended to reduce reporting obligations for smaller funds whilst ensuring the FCA continues to receive more detailed information from larger funds that may present greater potential risks to markets or investors. The consultation also proposes varying reporting frequencies, with larger managers generally expected to report more frequently than smaller or less complex firms.
This risk-based approach should help reduce unnecessary reporting burdens whilst providing the FCA with more consistent and higher-quality supervisory data.
Digital reporting and improved data quality
The FCA also intends to modernise the way firms submit regulatory data.
Alongside the consultation, the regulator has published prototype reporting templates to allow firms to begin testing the proposed reporting structure. Additional prototype forms are expected later this year before the FCA finalises the framework.
The regulator hopes that introducing a more consistent digital reporting approach will improve data quality, reduce reporting errors and allow firms to automate more of their reporting processes over time.
Who will be affected?
The proposals are expected to affect a broad range of firms operating within the UK asset management sector, including:
- UK AIFMs;
- UCITS management companies;
- authorised fund managers;
- operators of recognised overseas funds within scope; and
- third-country AIFMs marketing funds into the UK under the National Private Placement Regime (NPPR).
What should firms be doing now?
Although the reporting regime is not expected to be implemented until 2028, firms should begin considering the practical implications of the proposals.
In particular, firms may wish to:
- review existing regulatory reporting processes;
- identify where reporting data is currently sourced and validated;
- assess whether current systems can support the proposed reporting fields;
- consider opportunities to automate data collection and reporting; and
- respond to the consultation where the proposals may have operational or cost implications.
Early preparation is likely to make implementation significantly easier once the final rules are published.
How Complyport can help?
- Regulatory gap analysis: to assess existing reporting frameworks against the proposed FRAME requirements and identify areas requiring enhancement.
- Governance and reporting reviews: helping firms strengthen data quality, reporting controls and oversight arrangements before implementation.
- Implementation support: including assistance with policy updates, reporting processes, regulatory change management and readiness for the new reporting framework.
Contact Us
To discuss how the FCA’s proposals may impact your business, speak to one of our experts.
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