Knowledge Insiders

 Author: Paul van den Berg : June 2026

Developments in Asset Management Laws and Regulations
The regulatory landscape for asset managers continues to evolve rapidly, driven by shifting supervisory priorities and ongoing legislative initiatives. This edition highlights the most significant developments across accounting standards, supervisory reporting, sustainability frameworks, and investor disclosure requirements.

Regulatory Landscape Overview

Thresholds Up, Scrutiny Up?

Potential relief may be on the horizon for many US private fund advisers. The SEC’s proposed amendments to Form PF would significantly raise reporting thresholds, potentially removing around half of current filers from scope and reducing the population of large hedge fund advisers subject to enhanced reporting to roughly one-third of current levels.

However, this relief is only partial. Reporting requirements themselves are set to expand, and with a smaller reporting population, supervisory attention may become more concentrated. In addition, the proposed revisions aim to standardize responses across filers, making outliers more visible and therefore more likely to attract scrutiny and regulatory follow-up. 

In the UK, a comparable direction of travel is emerging. The FCA’s recent discussion paper on the future UK AIFM framework signals a similar recalibration, with a detailed consultation on revised rules expected next.

Simplification – over time

In mainland Europe, the focus is on longer-term simplification paired with enhanced oversight. On 4 May, the European Securities and Markets Authority (ESMA) released its final recommendations for a modernized and integrated reporting system for investment funds. Mandated under the revised AIFM and UCITS Directives, the proposal aims to replace today’s fragmented reporting landscape with a streamlined “report once” approach. The objective is to reduce operational burden for fund managers while simultaneously improving data quality, consistency, and supervisory effectiveness.

Data Quality

ESMA and NCAs apply dedicated Data Quality Engagement Frameworks (DQEFs) to both AIFMD and MMFR data, using risk based checks to improve accuracy, completeness, consistency, and timeliness through structured feedback and remediation. In 2025, per the report ESMA released on May 29, data quality has improved markedly across both regimes, with further enhancements planned for 2026, including stronger completeness checks and zero tolerance thresholds for key indicators.

IFRS

Potential relief may be on the horizon for many US private fund advisers. The SEC’s proposed amendments to Form PF would significantly raise reporting thresholds, potentially removing around half of current filers from scope and reducing the population of large hedge fund advisers subject to enhanced reporting to roughly one-third of current levels.

However, this relief is only partial. Reporting requirements themselves are set to expand, and with a smaller reporting population, supervisory attention may become more concentrated. In addition, the proposed revisions aim to standardize responses across filers, making outliers more visible and therefore more likely to attract scrutiny and regulatory follow-up.

In the UK, a comparable direction of travel is emerging. The FCA’s recent discussion paper on the future UK AIFM framework signals a similar recalibration, with a detailed consultation on revised rules expected next.

For a detailed overview of IFRS 18, including the key changes and the expected impact on financial reporting, please refer to our dedicated article on the website.

Dutch GAAP

RJ-Uiting 2026-1: Proposed Amendments to Guideline 611 Following the Future Pensions Act (Wtp)

Potential relief may be on the horizon for many US private fund advisers. The SEC’s proposed amendments to Form PF would significantly raise reporting thresholds, potentially removing around half of current filers from scope and reducing the population of large hedge fund advisers subject to enhanced reporting to roughly one-third of current levels.

However, this relief is only partial. Reporting requirements themselves are set to expand, and with a smaller reporting population, supervisory attention may become more concentrated. In addition, the proposed revisions aim to standardize responses across filers, making outliers more visible and therefore more likely to attract scrutiny and regulatory follow-up.

In the UK, a comparable direction of travel is emerging. The FCA’s recent discussion paper on the future UK AIFM framework signals a similar recalibration, with a detailed consultation on revised rules expected next.

RJ-Uiting 2026-3: Proposed Revisions to Guideline 217 ‘Consolidation’

On 7 April 2026, the RJ published RJ-Uiting 2026-3, containing a proposed revision of Guideline 217 Consolidation. The proposal aims to improve the structure, readability and accessibility of the guideline for entities assessing consolidation requirements and preparing consolidated financial statements. The proposed amendments are expected to become effective from 1 January 2027.

The proposed changes are primarily structural in nature and do not introduce substantive amendments to the existing consolidation requirements. The RJ proposes to reorganize the guideline by grouping presentation and disclosure requirements in a dedicated section, applying a more consistent chapter structure and making editorial improvements to enhance readability.

In addition, the RJ proposes several clarifications relating to key concepts used in determining the consolidation requirement and consolidation scope, including the definition of a group and the concept of dominant control. These clarifications are intended to support more consistent application of the existing requirements in practice and do not change the underlying principles.

RJ-Uiting 2026-5A: Proposed Amendments Following Comments on the 2026 RJ Guidelines

On 24 April 2026, the RJ published RJ-Uiting 2026-5A, containing a series of proposed amendments to the Dutch Reporting Guidelines following comments received on the 2026 RJ edition. The proposed changes are intended to clarify existing requirements, correct inconsistencies and improve the practical application of the Guidelines. The amendments are proposed to become effective from 1 January 2027.

The proposals cover a broad range of topics, including financial fixed assets, equity, financial instruments, income taxes, provisions and disclosure requirements. Most amendments are clarifications rather than substantive changes to existing accounting principles. Key proposals include clarification of the accounting treatment of participations without
significant influence, the presentation of realized revaluation gains, additional disclosure requirements relating to Pillar Two income taxes, and clarification of disclosures for financial assets carried at an amount above fair value.

Of particular relevance for financial institutions is the proposed clarification that participations without significant influence may be measured at fair value, with fair value changes recognized directly in profit or loss where permitted under Dutch law. The RJ also proposes additional disclosure requirements for entities that are liable for Pillar Two taxes, requiring such liabilities to be explicitly disclosed in the notes to the financial statements. Furthermore, the proposal clarifies disclosure exemptions available to medium-sized entities and provides additional guidance on the application of financial instrument requirements.

RJ-Uiting 2026-6: Proposed Amendments to the Dutch Reporting Guidelines Following IFRS 18

On 24 April 2026, the Dutch Accounting Standards Board (RJ) published RJ-Uiting 2026-6, containing proposed amendments to the Dutch Reporting Guidelines following the issuance of IFRS 18 Presentation and Disclosure in Financial Statements. While Dutch statutory reporting requirements limit the direct impact of IFRS 18 on Dutch GAAP financial statements, the RJ proposes several amendments to Guideline 360 Cash Flow Statement to improve consistency and comparability in cash flow reporting. The proposed changes are expected to become effective from 1 January 2027.

One of the key proposals concerns the application of the indirect method in the cash flow statement. The RJ proposes to clarify that the reported result used as the starting point for the reconciliation should correspond to a subtotal presented in the profit and loss account in accordance with the statutory reporting models. The RJ further proposes to define the term operating result, which is currently not defined in the Dutch Reporting Guidelines. These amendments are intended to promote greater consistency in the preparation of cash flow statements and improve comparability between reporting entities.

A second significant proposal relates to the presentation of interest and dividend cash flows. Under the current guidance, entities may choose whether to classify received and paid interest and dividends as operating, investing or financing cash flows. The RJ proposes to restrict these options by requiring received interest and dividends to be presented as investing activities and paid interest and dividends as financing activities. The proposal follows recent amendments to IAS 7 and aims to enhance comparability across financial statements.

The RJ acknowledges that for certain entities, investing in financial assets or providing financing forms part of their ordinary business activities. For these entities, including real estate investment companies and certain financing and
leasing entities, the proposed guidance would continue to allow interest and dividend cash flows to be presented as operating activities.

Supervisory Reporting

EU AIFMD (ESMA)

AIFMD II (Directive (EU) 2024/927) came into effect on 16 April 2026, marking the start of a significant evolution in supervisory reporting for alternative investment fund managers. ESMA is expected to deliver the revised reporting template within the next 12 months.

The updated framework will introduce several important changes:

    • Expanded operational disclosures, including more detailed information on delegation arrangements
    • Full-scope reporting, replacing the current focus on top exposures (e.g. moving from top 10 holdings to
      comprehensive investment exposure reporting)
    • A harmonized data format, with reporting to be submitted in a single XML structure

As highlighted in ESMA’s 4 May recommendations on the integrated collection of fund data, the new template will be developed in line with broader simplification and burden-reduction objectives, while supporting the transition towards a more integrated EU reporting architecture.

Towards an Integrated Reporting Framework

A central element of this evolution is ESMA’s proposed redesign of the EU supervisory reporting system, aimed at addressing the current fragmentation across jurisdictions and reporting regimes.

Key features of the proposed system:

 

    • “Report once” approach: Fund managers will submit data through a single national entry point, which will then feed into a centralized EU data hub managed by ESMA. This is intended to eliminate duplicative submissions to multiple authorities.
    • Modular reporting structure: The framework will move away from a one-size-fits-all template. All funds will complete core modules, with additional modules triggered only where relevant (e.g.  or specific asset classes or higher-risk strategies).
    • Common data dictionary: A unified regulatory data dictionary will standard definitions (such as NAV and AuM), ensuring consistent interpretation across jurisdictions and reporting regimes.
    • Standardized data format: Reporting will be based on the ISO 20022 XML standard, enabling automated validation and more efficient data exchange between authorities.
    • Increased data granularity: The system will move towards security-by-security (SbS) reporting, allowing supervisors to derive aggregate metrics directly and reducing the need for multiple manual breakdowns by fund managers.

Timelines and Implementation

ESMA has proposed a phased approach to implementation in order to manage complexity and reduce operational risk:

    • Phase 1 (expected 2029): Integration of AIFMD and UCITS supervisory reporting frameworks
    • Phase 2: Expansion to include Money Market Fund (MMFR) reporting and ECB statistical reporting

EU MMFR (ESMA)

On 5 May, ESMA published a consultation on its Guidelines on stress test scenarios under the Money Market Fund Regulation (MMFR), proposing a more streamlined approach to updating the calibration parameters used in MMF stress testing. The objective is to enhance responsiveness to market developments while reducing operational complexity for fund managers.

Consultation: Consultation on the Guidelines on stress test scenarios under the MMF Regulation

Separately, on 8 May, the European Commission published its report on the effectiveness of Regulation (EU) 2017/1131 in safeguarding the stability and resilience of the money market fund sector. Alongside the report, a Q&A was issued to clarify selected regulatory aspects and support consistent interpretation of the framework.

UK AIFMD (FCA)

Following the FCA’s discussion paper in 2023 on the future of the UK asset management framework, and the subsequent joint consultation by HM Treasury and the FCA in 2025, the market is now awaiting the next phase of policy development. These initiatives signal a broader shift towards a more tailored and proportionate regime, moving away from the on shored EU AIFMD framework while retaining core principles of investor protection and financial stability.

The FCA has indicated that it intends to launch a further consultation during 2026, focusing on more detailed rules and implementation aspects. This is expected to provide greater clarity on the design of the revised UK AIFM regime, including potential adjustments to thresholds, reporting requirements, and supervisory expectations.

Overall, the direction of travel points to a recalibrate framework that seeks to enhance the competitiveness of the UK asset management sector while maintaining robust regulatory oversight.

UK MMFR (FCA)

In 2023, HM Treasury and FCA consulted on replacing and reforming MMFR. On May 14, it was announced that the Government will now lay legislation as soon as parliamentary time allows to establish the new regulatory framework, under which most requirements for UK MMFs will be set out in FCA rules and guidance. This will include guidance setting out expectations that UK MMFs hold higher levels of liquidity. 

The UK’s new regime is expected to be in place by Q4 2026, subject to Parliamentary approval, and the FCA will issue a statement shortly with further details on its plans. The Government can confirm its intention to extend the Temporary Marketing Permissions Regime, with a view to establishing a longer-term solution on market access, in line with the UK’s framework and process for recognition of overseas firms and funds.

US Form PF (SEC/CFTC)

April 2026 Proposal – Recalibration, Not Rollback

The joint SEC–CFTC proposal released in April 2026 is best viewed as a recalibration of the 2024 Form PF amendments rather than a full reversal. While it removes some of the more operationally burdensome elements introduced in 2024 – before they could take effect – it does not eliminate the overall increase in reporting complexity. For large private fund advisers, the reporting effort is still expected to rise materially compared to the current framework.

A key feature of the proposal is the significant increase in reporting thresholds, alongside a targeted simplification of certain sections:

Proposed threshold changes

    • General reporting threshold: USD 1 billion in private fund AuM (up from USD 150 million)
    • Large hedge fund adviser threshold: USD 10 billion in hedge fund AuM (up from USD 1.5 billion)

Targeted adjustments to the current framework

    • Section 5 (Large Hedge Fund Advisers): Streamlined through the removal of selected items and clarification of reporting expectations
    • Section 6 (Private equity): Proposed elimination of quarterly event reporting, which the SEC now considers less relevant for assessing systemic risk

How the 2024 Package Has Been “Scaled Back”

The proposal reflects a policy course correction in response to industry feedback, focusing on removing the most operationally complex and costly elements of the 2024 amendments:

    • Elimination of high-frequency metrics: Requirements to report daily performance volatility and detailed monthly asset turnover have been removed, avoiding the need to capture highly granular transaction-level data.
    • More flexible look-through requirements: The rigid 2024 framework for calculating indirect exposures has been replaced with a more pragmatic approach based on reasonable estimates aligned with firms’ internal risk management practices.
    • Simplified counter party reporting: A streamlined counter party reporting structure is proposed, with elements of the revised Section 1b approach extended to other sections of the form.

Why the Reporting Burden Still Increases

Despite these simplifications, the proposal retains several core structural elements of the 2024 reforms, resulting in a structurally higher reporting burden for large advisers: 

  • Disaggregated (fund-level) reporting: The requirement to report on a fund-by-fund basis remains. This represents a significant shift from current practice, where many firms report aggregated data across fund structures.
  • Monthly reporting cadence: Key metrics – including counter party exposure, leverage, and asset class breakdowns – will continue to be reported on a monthly basis, increasing data collection and validation efforts.
  • More prescriptive data standards: Advisers will need to comply with more standardized definitions and calculation methodologies, including refined long/short exposure classifications and adjusted exposure metrics.
  • Heightened supervisory focus: By raising reporting thresholds and reducing the number of filers, the proposal effectively concentrates supervisory attention on the largest market participants. At the same time, greater standardization of data is likely to facilitate automated analysis, increasing the likelihood that inconsistencies and outliers are identified and challenged by regulators.

Overall Assessment

In effect, the April 2026 proposal trades breadth for depth: fewer firms will be subject to Form PF reporting, but those remaining in scope – primarily large, systemically relevant advisers – will face more granular, standardized, and closely scrutinized reporting obligations.

Consultation: Form PF Reporting Requirements (All Filers)

US CPO-PQR (CFTC/NFA)

Recent regulatory developments indicate a potential shift in the treatment of certain commodity pool operators (CPOs), alongside interim relief measures aimed at preserving operational continuity.

On 19 December 2025, the CFTC’s Market Participants Division issued No Action Letter 25 50, granting temporary relief from CPO registration for SEC registered investment advisers operating commodity pools offered exclusively to qualified eligible persons (QEPs). The relief is subject to specified conditions and is explicitly intended as an interim measure. Notably, it signals a potential policy reconsideration of former Rule 4.13(a)(4) – the “QEP Exemption” – which was withdrawn in 2012.

Subsequently, on 26 February 2026, the CFTC replaced this guidance with updated No Action Letter 26 06. The revised relief framework introduces greater operational flexibility by permitting deregistered CPOs to remain designated as the “Designated CPO” for their pools. This allows such entities to continue performing certain CPO functions despite deregistration, thereby supporting continuity in governance and compliance arrangements.

In addition, the updated relief clarifies that certain reporting elements will no longer be required, including the reporting of financial ratios previously expected under the CPO PQR framework. This change reflects a broader effort to streamline reporting obligations and remove data points that were viewed as less decision useful from a supervisory perspective.

Key Implications

    • Potential regulatory recalibration: The relief measures suggest a possible move towards reinstating a more proportionate regime for advisers managing QEP-only pools.
    • Operational continuity: The ability to retain the “Designated CPO” role mitigates disruption that would otherwise arise from deregistration.
    • Reduced reporting burden: The removal of financial ratio reporting, combined with deregistration relief, indicates a more focused approach to data collection.
    • Interim nature: As no-action relief is inherently temporary, firms should monitor further rule making or formal proposals that may codify – or reverse – this approach.

US Data Standards – SEC final rule on Financial Data Transparency Act joint data standards.

The SEC established joint data standards for data submitted to specified financial regulatory agencies, including common identifiers and principles for machine-readable data transmission. The related notice states the rule is effective 1 October 2026 and does not itself change reporting obligations until agencies take further implementation action.

The joint standards are designed to promote interoperability of financial regulatory data across the agencies by establishing common identifiers for entities, geographic locations, dates, and certain products and currencies.

This action is a first step towards implementing the Financial Data Transparency Act across federal financial regulatory agencies and will be followed by separate rule making for agency-specific standards that are aimed at further improving the accessibility of financial data.

The standards include a principles-based joint standard with respect to data transmission and schema and taxonomy formats, which would allow financial institutions to submit high-quality, machine-readable data to the agencies.

Cayman FAR MF/PF (CIMA)

Fee changes and tighter enforcement

In 2026, CIMA increased FAR-related fees and began integrating them into the annual fund fee structure. At the same time, there is a stronger emphasis on timely payment and filing, with penalties applied more systematically for late or outstanding FAR obligations.

Singapore QDC Reporting (MAS)

In Singapore, the Monetary Authority of Singapore (MAS) has introduced a new Quarterly Data Collection (QDC) framework, representing a significant shift towards more structured and data-driven supervisory reporting. The regime was introduced in late 2025 and became fully effective from Q1 2026, replacing the previous annual reporting approach.

QDC introduces a quarterly reporting cadence, with a two-tier structure comprising Basic QDC (applicable to all fund managers) and Full QDC (for firms managing funds or mandates with AuM of SGD 500 million). The framework requires the submission of more granular data on AUM, investor composition, investment exposures, and counter parties.

Fund Statistics Reporting

Euro area Investment Fund (IF) Reporting (ECB)

As outlined above under Supervisory Reporting, the current ECB statistical reporting framework for investment funds is expected to be replaced over time by a single, integrated EU-wide reporting mechanism. This transition forms part of the broader “report once” initiative led by ESMA and the ECB aimed at harmonizing supervisory and statistical data collection. Implementation of this new framework is not anticipated before 2029.

BCL (Luxembourg)

In Luxembourg, the Banque centrale du Luxembourg (BCL), in coordination with the CSSF, has implemented updates under Circular BCL 2024/245 and CSSF Circular 24/866, effective from late 2025 into early 2026.

The revised framework introduces:

    • New reporting templates aligned with ECB requirements
    • More frequent reporting cycles
    • Broader and more detailed data requirements

MESRAP (Netherlands)

In the Netherlands, De Nederlandsche Bank (DNB) continues to develop MESRAP (Macro Economic Statistics
Reporting) as the core framework for investment fund statistical reporting.

Recent developments include:

    • Implementation of updated MESRAP taxonomy (v4.0.0)
    • Higher reporting frequency across selected datasets
    • Stricter validation and data quality controls
    • Enhanced supervisory focus on timeliness and completeness, supported by updatedenforcement measures taking effect in August 2026

Pensions Reporting

Netherlands FTK/ WTP (DNB)

De Nederlandsche Bank (DNB) has implemented Taxonomy 5.0 for FTK and WTP reporting, applicable to 2026 submissions. This represents a key step in aligning existing supervisory reporting under the Financieel Toetsingskader (FTK) with the new requirements under the Wet toekomst pensioenen (WTP).

Key changes include:

    • New and revised reporting templates: Updates across investment, risk, and participant data, reflecting evolving supervisory requirements and alignment with the WTP framework.
    • Expanded look through and classification requirements: Increased granularity, including:
    • More detailed asset categorization
    • Enhanced counter party reporting
    • Specific classification of new asset classes, such as crypto assets

Consumer Disclosures

EU PRIIPs KID (ESAs)

The European Supervisory Authorities (ESAs) published an updated consolidated PRIIPs Q&A on 5 December 2025, providing further clarification on key elements of the framework, including the summary risk indicator (SRI), performance scenarios, and cost calculation methodologies. The objective is to promote more consistent application of the existing PRIIPs regime across jurisdictions and manufacturers.

In parallel, ESMA has continued to advance its broader work on retail investor disclosures. In a statement issued in March 2026, ESMA emphasized the need to simplify and streamline disclosures, improve comparability for retail investors, and further enhance digital delivery channels. These themes are expected to inform future revisions of the PRIIPs framework and related disclosure requirements.

UK CCI (FCA)

In the UK, the FCA published its final rules for the Consumer Composite Investments (CCI) regime on 8 December 2025, introducing a new domestic framework for retail product disclosures.

The regime formally came into effect on 6 April 2026, marking the start of an optional transitional period. During this period, firms may either:

    • Adopt the new CCI product summary disclosure, or
    • Continue using existing EU-derived PRIIPs KID and UCITS KIID disclosures

The transitional period runs until 8 June 2027, after which the CCI disclosure requirements will become mandatory, fully replacing PRIIPs and UCITS-based disclosures in the UK.

The CCI regime is intended to deliver simpler, more flexible, and more consumer-focused disclosures, with an increased emphasis on clarity, usability, and digital presentation.

Insurance Reporting

EU Solvency II (EIOPA)

In 2026, EIOPA has progressed the Solvency II review with a strong focus on reducing supervisory reporting and disclosure requirements.

On 30 March 2026, EIOPA published its final report proposing amendments to the supervisory reporting and disclosure Implementing Technical Standards (ITS). These proposals aim to reduce reporting burdens by:

    • Reducing the number of templates and data points
    • Lowering reporting frequency for selected templates
    • Applying proportionality more systematically, particularly for smaller and less complex undertakings

Overall, the proposed changes are expected to reduce:

    • ~26% of quarterly templates (up to ~36% for small firms)
    • ~30% of annual templates
    • ~22% of data points

In parallel, EIOPA launched a consultation on 15 April 2026 focusing on the shortening of 13 sets of Solvency II Guidelines, with the explicit objective of simplifying requirements and reducing administrative burden.

Consultation: Consultation on the shortening of additional Guidelines under Solvency II

The consultation covers both Pillar I and Pillar II areas (including governance and ORSA) and targets a minimum 25% reduction in length, without introducing new substantive requirements.

TPT

Meanwhile, also FinDatEx advised to be working on V8 of TPT, and which would contribute to simplification with the proposed elimination of ~ 20 data points out of 158 existing ones. The envisaged timeline is:

  • June – September: consultation, feedback processing, finalization
  • Q1 2027: implementation

Sustainability

EU SFDR/CSRD (ESAs)

The EU sustainable finance framework is currently undergoing a period of recalibration, driven by the European Commission’s broader “Omnibus” simplification agenda. This initiative aims to reduce complexity, improve the usability of disclosures for investors, and alleviate operational burdens for firms. In parallel, recent developments under the Corporate Sustainability Reporting Directive (CSRD) – particularly the increasing availability of more standardized sustainability data and ongoing discussions at EU level on streamlining reporting requirements – are expected to play a key role in improving the consistency and effectiveness of product-level disclosures under SFDR.

At the center of this transition is the ongoing review of the Sustainable Finance Disclosure Regulation (SFDR). The review is expected to move the framework towards a more coherent and streamlined regime, addressing persistent challenges around product classification (notably Articles 8 and 9), data availability, and the overall effectiveness of sustainability disclosures.

Supervisory developments and ESMA messaging

On 6 May 2026, ESMA published a statement following its Common Supervisory Action (CSA) conducted with national competent authorities (NCAs) during 2024–2025, focusing on the integration of sustainability into MiFID II suitability assessments and product governance processes.

Key takeaways from ESMA’s communication include:

    • Continued priority on sustainability integration: ESMA reaffirmed that the integration of sustainability risks and preferences into suitability and product governance frameworks remains a key supervisory priority, and firms are expected to continue progressing their implementation of MiFID II requirements.
    • Recognition of an evolving SFDR framework: ESMA explicitly acknowledged that the SFDR regime is in transition and is likely to undergo significant changes, which will reshape sustainability-related product disclosures.
    • Alignment with MiFID II requirements: A revised SFDR framework is expected to trigger corresponding updates to MiFID II sustainability preference rules, strengthening the link between product disclosures and distribution requirements.
    • Focus on simplification and usability: Across its messaging, ESMA emphasized the need for simpler, clearer, and more decision-useful disclosures, both for investors and market participants.

Supervisory approach during transition

Reflecting this evolving landscape, ESMA has called on NCAs to adopt a proportionate and pragmatic supervisory approach:

    • Supervisors are encouraged to priorities dialogue with firms to address shortcomings identified in the CSA
    • Enforcement action should be targeted, focusing on cases of clear breaches or mis-selling

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