Knowledge Insiders

 Author: DM Technical Team : November 2025

Regulators across Europe and the United States continue to refine reporting frameworks to reduce unnecessary burden, while at the same time increasing expectations around data quality, transparency and governance. Below is a clear summary of the most relevant updates for asset managers as of November 2025.

Overall Regulatory Direction

Across recent proposals and drafts, a consistent theme is emerging: simpler rules, stronger supervision.

Frameworks such as SFDR, CSRD and Form PF are being streamlined, but regulators are becoming more data driven and more focused on greenwashing risks, liquidity management and accurate digital reporting.

 

Accounting Standards

IFRS
  • The IASB updated its going concern educational material to reflect IFRS 18 and ISA 570 (Revised 2024).
  • Amendments to IFRS 19 introduce reduced disclosure requirements for areas such as supplier finance arrangements, Pillar Two rules and non-current liabilities with covenants.
  • These amendments take effect from 1 January 2027.
Dutch GAAP
  • The 2026 RJ edition reorganises guidance for entities applying IFRS alongside Dutch Civil Code rules and updates Chapter 400 to align with the revised Dutch Corporate Governance Code.
  • A new mandatory Risk Management Statement (VOR) now applies to companies within the scope of the Code.
  • RJ Notification 2025 11 outlines progress on CSRD implementation, with varying start dates depending on company size.
US GAAP
  • ASU 2025 05 provides practical relief for estimating credit losses on receivables and contract assets.
  • ASU 2025 08 simplifies the CECL model for certain purchased loans that do not show credit deterioration.
  • Both updates are effective for periods beginning on or after 15 December 2025.

AIFMD and Supervisory Reporting

EEA
  • ESMA added new Q and A items on AIFMD scope but with no impact on Annex IV reporting.
  • Work has begun on a future integrated reporting system for AIFMD and UCITS, aimed at reducing duplication and promoting a report once approach.
UK
  • The UK is replacing AUM thresholds with a new three tier model based on net asset value.
  • Draft legislation is expected later in 2025, with FCA rules to follow in 2026.
Form PF (United States)
  • The compliance date for the new sections has been pushed to 1 October 2026.
  • The SEC may revise or reconsider the amendments before implementation.

Other Regulatory Reporting

New EU requirements under ECB 2024 17 will apply from January 2026, although some national authorities are offering a brief transition period before full compliance. In the Netherlands, DNB has released Taxonomy 5.0 for FTK and WTP reporting, introducing new schedules, updated classifications and tighter assertion requirements for pension fund reporting. This taxonomy applies to all 2026 submissions as well as selected year end 2025 reports.

PRIIPs and Retail Disclosure

Within the EU, ESMA published an updated PRIIPs Q and A in May 2025 and further simplification is anticipated as part of the broader PRIIPs review currently underway. In the UK, the FCA is progressing with plans to introduce the Consumer Composite Investments framework, which will replace the existing UK PRIIPs and UCITS disclosure rules. The new format is not expected to take effect before mid-2027.

Sustainability Regulations

The European Parliament has supported a significant package of changes that simplify both CSRD and ESRS. These changes narrow the scope of CSRD to only the largest companies, reduce the level of required disclosure detail, make sector standards voluntary and limit due diligence obligations to very large groups. They also restrict how much information large companies can demand from SME suppliers. Overall, the package aims to reduce administrative burden and ensure a more proportionate approach to sustainability reporting.

A leaked draft of SFDR 2.0 indicates an extensive redesign of the framework. The draft proposes removing the current Article 8 and 9 classifications and replacing them with three mandatory product categories focused on transition, integration of sustainability factors and sustainability objectives. It introduces a minimum alignment threshold of 70 percent and mandatory exclusions, removes entity level PAI disclosures and provides an option for professional investor AIFs to opt out of the product categorisation regime. Final rules are expected between 2027 and 2028.

Summary

Regulation is moving toward simpler and more streamlined disclosure frameworks, while supervision is becoming more targeted, data driven and focused on accuracy. Asset managers should expect continued consolidation of reporting requirements, closer scrutiny of ESG claims and liquidity management, and a shift toward more digital and standardised regulatory reporting across major markets.

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