On 14 July 2026, the FCA set out the biggest change to the UK AIFM regime since onshoring, and it lands hardest on how you’re sized and how you report.
Firm classification would move from AUM to aggregate NAV, sorting AIFMs into three proposed tiers: small (below £750M), medium (£750M to £5B), and large (above £5B). Annex IV gives way to FRAME (Fund Reporting for Asset Management Entities), a UK-built regime where smaller funds report less and larger ones report more, with a £500M cut-off. Your EU Annex IV doesn’t disappear either; dual-regulated managers would run both, divergently.
So why act now, when the effective date is years away?
Because by the time final rules land in 2027, you should already be ready, not starting. From day one, you must know your tier, evidence it on demand, and notify the FCA the instant you cross a threshold. There’s no grace period: your tier rests on aggregate NAV, tracked across every fund and defensible under scrutiny. For most managers, that figure lives in fragments today, and rebuilding it is a data-architecture project that runs in quarters, not weeks.
Where does your current setup break under the new rules, and what does it take to make your tier defensible before a regulator asks? This session walks through both, drawing on two decades of regulatory reporting work across the UK, EU and US at Indus Valley Partners.
