FCA Asset Management Reform: The £128m Rulebook Package

ByOfficer

On 14 July 2026 the Financial Conduct Authority opened three linked consultations that together make up its asset management reform package, a set of proposals the regulator estimates would save UK asset managers around £128m a year. The three papers cover fund reporting, the alternative investment fund manager regime, and the remuneration rules that apply to firms the FCA supervises on its own. None of them is a final rule yet. Each is a consultation with a fixed response window, and those windows close between 16 September and 14 October 2026.

The FCA asset management reform is being pitched as proportionality in action: fewer overlapping obligations, reporting tailored to the size and risk of a firm, and a simpler perimeter for smaller managers. Simon Walls, the FCA’s executive director for markets, described the proposals as “a practical example of the FCA’s strategy in action”, aimed at better supervisory data and lower industry costs. For reporting and compliance teams, the near-term work is a consultation-response exercise, not a re-plumbing of live returns.

Related reading: AIFMD II Annex IV reporting changes, which sets out the parallel direction the EU has taken on alternative fund reporting.

The consultation calendar at a glance

The value of this package sits in the response deadlines, so the calendar is the first thing to pin down:

  • 14 July 2026: the FCA publishes the reform package and opens all three consultations.
  • 16 September 2026: responses close on the remuneration consultation (CP26/27).
  • 22 September 2026: responses close on the FRAME fund reporting consultation (CP26/26).
  • 14 October 2026: responses close on the UK AIFM regime consultation (CP26/28), with an earlier deadline of 18 September 2026 for the discussion chapters in that paper, other than the prudential reforms.
  • First half of 2027: the FCA expects to publish a policy statement with final FRAME rules, according to the FRAME consultation.

A firm that files nothing during the windows forgoes the chance to shape rules that will land later. Treat the calendar as an engagement deadline, not a reporting one.

FCA asset management reform: three consultations, one direction of travel

The package is three separate consultation papers that share a theme. CP26/26 proposes a new fund reporting model called Fund Reporting for Asset Management Entities, or FRAME. CP26/27 proposes to reform the remuneration rules for firms the FCA regulates on a solo basis. CP26/28 proposes to modernise the UK regime for alternative investment fund managers, much of which is inherited from rules that arrived with the Alternative Investment Fund Managers Directive back in 2013. The connective tissue is proportionality, and the FCA has said that a large share of the projected £128m annual saving is expected to come from the FRAME reporting changes.

FRAME: the reporting change carrying a large share of the savings

FRAME is the strand a reporting officer will feel first. Under CP26/26 the FCA proposes to replace current fund reporting requirements with consolidated forms, reduce the need for some notification requirements and make reporting proportionate to fund size and risk. For AIFs and UK UCITS within the core FRAME model, funds below £500m NAV would submit the essential requirements, while funds at or above £500m NAV would submit enhanced requirements in addition to the essential set. RVECA, SEF and recognised schemes would submit the essential set only, while reporting frequency and submission lag would vary by fund type.

It helps to be precise about what FRAME is and is not. FRAME is a proposed UK reporting framework whose perimeter extends beyond UK AIFMs. CP26/26 would apply fund-level reporting to FCA-authorised UK AIFMs for all AIFs they manage, RVECA and SEF managers, UK UCITS management companies for UK UCITS, third-country AIFMs marketing unauthorised AIFs in the UK under the National Private Placement Regime, and operators of Overseas Funds Regime funds and individually recognised section 272 schemes. It also proposes separate annual reporting for some MiFID investment managers and advisers, including collective portfolio management investment firms, and for operators of collective investment schemes. FRAME remains distinct from EU AIFMD supervisory reporting, so firms with both UK and EU obligations must map the regimes separately.

The AIFM regime: from AUM thresholds to a graduated structure

CP26/28 proposes a graduated three-tier structure based on the aggregate net asset value of all AIFs managed. Under the draft ALTS rules, the AIFM would aggregate the NAVs of all AIFs it manages using the calculation methodology set out in CP26/28. The proposed thresholds are below £750m for small, £750m to £5bn for medium, and above £5bn for large.

One point is easy to misread. Removing the old thresholds does not mean the same rulebook for every manager; the proposal is graduated by design, so a large manager and a small one would face different levels of requirement under the same regime. There is also a legislative dimension the FCA cannot deliver alone: HM Treasury is running a parallel consultation on the underlying legislation, so the full picture spans the FCA rulebook and the statutory framework beneath it.

Remuneration: one framework instead of overlapping codes

CP26/27 proposes to replace SYSC 19B, SYSC 19E and SYSC 19G with a new consolidated solo-regulated firms remuneration code. At commencement, the proposed code would apply to full-scope UK AIFMs, UK UCITS management companies that manage a UCITS scheme, and non-SNI MIFIDPRU investment firms.

Scope changes in two stages. The consultation concerns the FCA’s solo-regulated remuneration code, not the PRA/FCA dual-regulated code. The new code would initially apply to full-scope UK AIFMs, UK UCITS management companies and non-SNI MIFIDPRU investment firms. Once the wider AIFM reforms take effect, AIFM scope would transition to medium and large UK AIFMs, while UK UCITS management companies and non-SNI MIFIDPRU investment firms would remain in scope. Firms should assess the effect on their material risk taker population and remuneration governance against the proposed new consolidated code.

What the package is not: a live compliance deadline

The September and October 2026 dates are consultation closing dates, not compliance go-live dates. For FRAME, the FCA aims to issue further prototype forms before the end of 2026, publish final rules in the first half of 2027, and have the regime fully implemented in 2028. For remuneration, the FCA anticipates a policy statement in Q1 2027. The proposed rules and guidance would come into force the following day and would apply to remuneration relating to performance periods beginning on or after commencement; AIFMs would transition in two stages in line with the wider AIFM reforms. For the AIFM regime, the FCA plans a second consultation on remaining areas and currently envisages implementation in 2028. Firms should assess and respond now, but build against final rules and implementation dates when published.

How the UK path compares with the EU’s AIFMD II

UK managers with an EU footprint will read this package against the EU’s own revision of the alternative fund framework, and the two are diverging by design. The EU has amended the Level 1 framework through AIFMD II, including supervisory reporting and liquidity management tools. The detailed future reporting templates, timing, frequency, format and identifiers depend on further regulatory and implementing technical standards, so firms should not treat the technical EU reporting build as final. The UK, no longer bound to mirror the directive, is reshaping the inherited rules on its own terms; the FRAME model in particular is a UK-specific construct, so a change on one side does not map onto the other. The reform fits a wider FCA pattern of proportionate rule-making, visible in its recent work on the UK money market fund regime and the Senior Managers and Certification Regime reforms.

What UK-regulated managers should check now

The productive summer task is a mapping exercise across three questions. Classification: under the proposed CP26/28 methodology, which tier would the aggregate NAV of the AIFs managed place the firm in, and what would change at that level. Reporting: which current returns and notifications would be absorbed into the FRAME consolidated forms under CP26/26, and where the firm’s data model would need to flex. Remuneration: if the firm is solo-regulated and within the CP26/27 perimeter, which existing code it applies today, how the proposed framework would apply general requirements to all staff and targeted requirements to material risk takers, and (where the firm is a MIFIDPRU firm) the effect of the proposed revocation of MIF008 and deletion of the MIFIDPRU 8.6 remuneration disclosures. Each check produces a concrete input to a consultation response.

Frequently Asked Questions

Are the September and October 2026 dates compliance deadlines?

No. They are the dates by which responses to the three consultations must reach the FCA. The rules are still proposals. Firms that miss the windows lose the opportunity to influence the drafting. Compliance dates come later, once the FCA finalises each strand.

Which firms fall within the remuneration consultation (CP26/27)?

At commencement, the proposed solo-regulated firms remuneration code would apply to full-scope UK AIFMs, UK UCITS management companies and non-SNI MIFIDPRU investment firms. Once the wider AIFM reforms take effect, the AIFM population would transition to medium and large UK AIFMs. The consultation does not replace the separate remuneration framework for PRA/FCA dual-regulated firms.

Does removing the AUM thresholds mean one rulebook for all AIFMs?

No. CP26/28 proposes graduated requirements based on the aggregate NAV of the AIFs managed: below £750m for small AIFMs, £750m to £5bn for medium AIFMs and above £5bn for large AIFMs. The three tiers carry graduated requirements; consult CP26/28 for any provisions on voluntary election into a higher tier.

Is HM Treasury involved?

Yes for the AIFM regime. The FCA is consulting on its rules while HM Treasury runs a parallel consultation on the underlying legislation. The two together determine the final shape of the UK AIFM framework.

Is FRAME the same as the EU’s AIFMD Annex IV return?

No. FRAME is a UK domestic reporting model proposed in CP26/26, covering what UK asset management entities report to the FCA. It is distinct from EU AIFMD Annex IV reporting.

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Key Takeaways

  • On 14 July 2026 the FCA opened three linked consultations forming its asset management reform package, with an estimated £128m in annual savings for UK asset managers.
  • The three papers are CP26/26 (FRAME fund reporting), CP26/27 (remuneration for solo-regulated firms), and CP26/28 (the UK AIFM regime).
  • Response deadlines are 16 September 2026 (remuneration), 22 September 2026 (FRAME) and 14 October 2026 (AIFM regime), and an earlier 18 September 2026 date for CP26/28 discussion chapters. These are consultation closing dates, not compliance go-live dates.
  • FRAME would replace current fund reporting with consolidated forms and more proportionate requirements for managers of smaller funds, and is expected to account for a large share of the projected saving.
  • CP26/28 proposes a three-tier AIFM structure based on aggregate NAV, with HM Treasury consulting in parallel. CP26/27 would initially apply to full-scope UK AIFMs, UK UCITS management companies and non-SNI MIFIDPRU investment firms; once the wider AIFM reforms take effect, AIFM scope would transition to medium and large UK AIFMs.

Sources and References

  • FCA press release, “Streamlined rulebook to save asset managers £128m a year”, 14 July 2026: fca.org.uk
  • FCA CP26/28: The UK AIFM Regime (consultation, closing 14 October 2026): fca.org.uk
  • FCA CP26/26: Fund Reporting for Asset Management Entities (FRAME) (consultation, closing 22 September 2026): fca.org.uk
  • FCA CP26/27: Remuneration: Solo-regulated firms’ rules reform (consultation, closing 16 September 2026): fca.org.uk

Engaging before the window closes

The FCA asset management reform is, for now, an invitation to comment on where the UK rulebook should land. The firms that get the most from it will treat the September and October 2026 windows as a chance to test their own classification, reporting and remuneration positions against the drafts, and to say so on the record. The implementation work follows later, once the FCA turns three consultations into finished rules.

Last updated: July 2026

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.

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