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News – 11.07.25
Buzzacott has been ranked 30th in the Sunday Times Top 100 Apprenticeship Employers 2025!
Buzzacott has been ranked 30th in the Sunday Times Top 100 Apprenticeship Employers 2025 … Read more
Insight – 09.07.25
The importance of ISAE 3402 reports in risk management
Undertake a ISAE 3402 report to help mitigate risk and improve stakeholder trust. … Read more
Upcoming event – 22.07.25
'Aligning purpose with performance' - a joint webinar by Buzzacott and Rathbones
'Aligning purpose with performance' - a joint webinar by Buzzacott and Rathbones … Read more
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Central to the proposed reforms is a shift from gross Assets under Management (AuM) to NAV as the basis for regulatory thresholds. The new regime will introduce three categories of AIFMs:
| Category | NAV | Outcome |
| Small AIFMs | NAV < £100 million | AIFMs in this category will benefit from a simplified, baseline regulatory framework. |
| Medium AIFMs | £100 million > NAV > £5 billion | The broad category that encompasses the majority of UK managers will be the focal point of new risk-based rulemaking. |
| Large AIFMs | NAV > £5 billion | AIFMs in this category will remain subject to a full-scope regime, albeit with some outdated requirements removed. |
The FCA is expected to introduce a layered approach within the mid-tier category to avoid the current “cliff-edge” effects, ensuring that regulatory burdens are proportionate to the scale and risk profile of each firm.
Prudential requirements: recalibration of capital buffers is under consideration, particularly for firms with MiFID top-up permissions.
Remuneration codes: A proposal has been put forward to streamline the current patchwork of overlapping codes (AIFM, UCITS, MIFIDPRU) into a unified framework.
Regulatory reporting: The FCA aims to reduce duplication, eliminate redundant returns, and enhance the clarity and utility of data collection.
Leverage: The FCA is expected to align more closely with the Financial Stability Board’s standards for non-bank institutions, introducing stricter risk management, stress testing, and disclosure requirements for highly leveraged firms.
Other areas: Disclosures, depository engagement, and external valuer liability are likely to be addressed in forthcoming consultation papers.
While the direction of travel is clear, the path forward is complex. The FCA faces the challenge of designing a regime that accommodates diverse risk profiles within the mid-tier category. Industry stakeholders are encouraged to engage actively with both the Treasury’s consultation and the FCA’s “Call for Input” to help shape a regulatory framework that is proportionate, effective, and globally competitive.
As the UK moves toward a unified asset management regime, firms should prepare for a period of significant change - one that promises long-term benefits but will require careful navigation in the months ahead.
If you have any questions about your requirements under AIFMD or would like more information on our support options for FCA regulated firms, don’t hesitate to contact us. Fill in the form below to speak to one of our experts.
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