UK/EU Investment Management Update (August 2026)

1. UK – Asset Management Reform 
2. UK – MiFIR Transaction Reporting 
3. UK – Financial Crime 
4. UK – Consumer Duty 
5. UK – Tax 
6. UK – Cryptoassets 
7. UK – Consolidated Tape 
8. UK – Enforcement 
9. EU – AIFMD/UCITS 
10. EU – CSDR 
11. EU – EMIR 
12. EU – Consolidated Tape 
13. EU – Capital Markets Data 
14. EU – Regulatory Q&As 
15. EU – Sanctions 
16. EU – Artificial Intelligence 
17. EU – ESG 
18. International – ESG 

1. UK – Asset Management Reform

FCA consults on a streamlined asset management rulebook

On 14 July 2026, the FCA published a package of consultations intended to tailor its requirements for asset managers, cut costs for firms, and improve the data the FCA collects to supervise the sector. The FCA estimates that the package will save asset managers approximately £128 million a year, with a large share of the savings expected to come from a new, more targeted fund reporting regime. 

The package delivers proposed reform of the UK Alternative Investment Fund Managers Directive (AIFMD) regime that the FCA had signalled in its private markets work and Regulatory Initiatives Grid, as covered in our June 2026 Update, comprising three linked consultations of direct relevance to UK asset management firms:

• UK AIFM Regime (CP26/28). The FCA proposes to modernise and simplify the AIFMD-derived rules, and to replace them with a more flexible, tailored and proportionate framework, while maintaining clear standards. Key proposals include:
  • New three-tier NAV-based regime. Alternative Investment Fund Managers (AIFMs) to be categorised with graduated requirements based on aggregate Net Asset Value (NAV) as Small (<£750 million), Medium (£750 million to £5 billion) or Large (>£5 billion) AIFMs. This represents a change from the current thresholds that are calculated by assets under management.
  • Valuation. Small AIFMs will only be subject to certain baseline requirements, such as the obligation to ensure valuations are carried out properly and in good faith, at fair value. Small and Medium AIFMs need to ensure that valuations are carried out “separately” from the portfolio management function. Only Large AIFMs will be required to ensure that valuations are carried out “independently” of the portfolio management function.
  • Leverage. Removal of gross/commitment method – more flexible disclosure to investors based on a general “fair, clear and not misleading” standard.
  • Delegation. Removal of the need for AIFMs to seek prior approval to delegation arrangements (set out in the draft AIFMR 2026 discussed below), with the FCA proposing that AIFMs notify it of delegation arrangements as soon as possible. 
  • Pre-contractual disclosures (current Article 23 supplement). Move from prescriptive to principles-based regime, to apply to AIFMs of all sizes (unless there are retail investors); includes reductions to mandatory pre-contractual and periodic disclosures.
  • AIF annual report. Removal of “all staff” remuneration disclosure requirements and limiting disclosure to Material Risk Takers (MRTs) only.
  • National Private Placement Regime (NPPR). HMT proposes to retain the NPPR in primary legislation with limited changes.
  • AIFM business restriction. Removal of business restriction (AIFMs are currently permitted to carry on only certain Markets in Financial Instruments Directive (MiFID) activities; in particular, an AIFM is not able to execute orders on behalf of others).
  • Reviewing the prudential regime for fund managers. Consulting on bringing fund managers within the scope of the new Core Prudential Sourcebook (COREPRU). COREPRU is the integrated prudential framework the FCA has developed as the common baseline for firms subject to FCA prudential regulation.

The consultation closes on 14 October 2026, although certain chapters (e.g. AIFM business restriction) have an earlier deadline of 18 September 2026.

●  Fund Reporting for Asset Management Entities (FRAME) (CP26/26). The FCA proposes a new fund reporting regime to improve the quality and consistency of data reported to the FCA by replacing the current reporting requirements with a single framework calibrated to the type, size and activity of the fund (with “Essential” and “Enhanced” features). Key proposals include: