The Financial Conduct Authority’s latest asset-management package follows its April 2025 discussion paper and sits alongside HM Treasury’s parallel work on the underlying legislation, before a new UK regime currently envisaged for 2028.
The package combines consultations on the UK Alternative Investment Fund Managers regime, Fund Reporting for Asset Management Entities and remuneration, with the FCA estimating annual industry savings of £128 million.
Under CP26/28, the FCA proposes reworking the current Alternative Investment Fund Managers Directive framework through a three-tier structure for small, medium and large firms. Most requirements would be brought into a new Alternative Investment Funds sourcebook, known as ALTS, with rules applied according to a firm’s size, activities and risk.
The regulator says UK managers oversee almost £2 trillion in alternative assets and more than £16 trillion across the wider asset-management sector. CP26/26 would introduce FRAME, consolidating existing reporting forms, reducing some notification requirements and applying lighter obligations to managers of smaller funds.
The proposals extend beyond full-scope alternative investment fund managers. FRAME would also cover UK UCITS management companies, third-country managers using the National Private Placement Regime, operators of funds recognised through the Overseas Funds Regime, managers of Registered Venture Capital Funds and Social Entrepreneurship Funds, and some MiFID investment managers and advisers.
CP26/27 would replace three remuneration codes with one consolidated, outcomes-focused code for in-scope solo-regulated firms, including non-SNI MIFIDPRU investment firms. Simon Walls, the FCA’s executive director of markets, said the changes were intended to improve supervisory data while reducing unnecessary cost.
Financial-services solicitors and in-house counsel should now map each regulated entity, fund and delegation arrangement against the proposed perimeter rather than treating the package as one reporting exercise. Firms will need to test which ALTS tier would apply, identify FRAME data that existing systems cannot produce reliably, review governance around pay decisions and assess whether employment terms, bonus structures and deferral arrangements remain workable.
Advisers to overseas managers should also examine UK marketing routes under the National Private Placement Regime and Overseas Funds Regime, while boards serving retail clients should record how any reduction in process preserves consumer protection and market integrity.
The timetable requires separate responses. CP26/27 closes on 16 September 2026, most CP26/28 discussion chapters close on 18 September, FRAME closes on 22 September and the main AIFM consultation closes on 14 October.
The FCA expects a FRAME policy statement in the first half of 2027 and a remuneration policy statement in the first quarter of 2027, while HM Treasury and the FCA must still settle the legislation, final rules and transitional arrangements before the proposed 2028 implementation.