The FCA's consultation paper CP26/26 proposes one of the most significant changes to UK fund reporting since the introduction of Annex IV under AIFMD.

The proposed Fund Reporting for Asset Management Entities (FRAME) framework will replace Annex IV and several other existing returns with a single reporting regime designed to collect more consistent, meaningful, and proportionate information from the UK asset management sector.

The FCA has presented the proposals as a significant step towards simplifying regulatory reporting, estimating a 75% reduction in reporting burden across the sector. However, the reality is more nuanced. While many smaller funds are likely to benefit from significantly lighter reporting obligations, larger and more complex funds should expect a ‘different’ reporting regime rather than necessarily a smaller one. Overall, the proposals point towards a proportionate framework, with less emphasis on regulatory calculations and greater reliance on existing data. This article outlines the important things to know about FRAME.

A single reporting framework across multiple sectors

FRAME is not simply a replacement for Annex IV.

The proposals bring together several previously separate reporting regimes into a single framework. They also apply that framework across a broader range of fund structures, including:

• UK AIFMs, UK UCITS management companies

• Managers of Registered Venture Capital Fund (RVECA) and Social Entrepreneurial Fund (SEF) vehicles

• Operators of recognised schemes

• Third-country AIFMs marketing into the UK through the National Private Placement Regime (NPPR)

The inclusion of UK UCITS managers is particularly noteworthy. Historically, FCA visibility over UCITS funds has been significantly narrower than its oversight of AIFs. Under FRAME, UCITS funds become a much more visible part of the reporting landscape through regular fund-level reporting. This suggests the FCA is seeking a more comprehensive view of risks and investor activity across the wider market rather than simply reforming the AIFMD reporting regime.

A proportional approach built around fund size

The proposed framework introduces two reporting tiers based on fund Net Asset Value (NAV).

Funds below £500 million NAV would fall within the Essential Reporting regime, which aims to capture baseline yet fundamental information relating to the funds. Funds at or above that threshold would be subject to Enhanced Reporting requirements, which introduce more detailed data requirements, particularly around investors, liquidity, portfolio composition and financing arrangements. The FCA estimates that approximately 90% of funds currently reporting would remain within the Essential category.

To support implementation, firms would not move immediately between tiers when crossing the threshold. The proposals provide a two-quarter transition period for firms that report quarterly and a one-year transition period for firms that report annually before Enhanced Reporting becomes mandatory. Firms may also voluntarily opt into Enhanced Reporting where a consistent reporting approach across multiple funds would be beneficial or they foresee that a fund is likely to grow above the threshold.

Although the framework is intended to be proportionate, firms should be cautious about focusing solely on the £500 million threshold. The gap between Essential and Enhanced Reporting is significant. To understand the full scope of differences, see our article on what the FCA's reporting template means for firms.

Reporting frequency linked to fund characteristics

FRAME also replaces the current manager level reporting frequency model with one based on the nature of the fund itself.

Following implementation, authorised funds and unauthorised funds that are categorised as hedge funds would report quarterly, while all other unauthorised AIFs would move to annual reporting. The FCA's rationale is that the reporting frequency should reflect the liquidity profile and potential risk characteristics of the underlying fund rather than the size of the manager responsible for it.

The proposals also provide longer submission windows than many firms currently work with under Annex IV, which should improve both operational efficiency and data quality. For many managers, particularly in private markets, reduced reporting frequency and longer submission periods may represent some of the most tangible benefits of the new framework.

Fund classification will matter

One aspect of the proposals that warrants close attention is fund classification.

Several reporting requirements depend on how a fund is categorised, including reporting frequency, Enhanced Reporting requirements and, in some cases, Event-Based Reporting obligations. While the FCA has proposed definitions for categories such as hedge funds, loan origination funds, and private market funds, some of those definitions have the potential to overlap.

As a result, firms may wish to begin by considering how their existing fund range aligns with the proposed categories and monitor future FCA clarification as the consultation develops.

Moving away from Annex IV leverage calculations

One of the most significant conceptual changes in CP26/26 is the FCA's decision to move away from Gross and Commitment leverage calculations.

The regulator has concluded that these metrics often provide limited insight into the underlying risks within a fund. Instead, FRAME focuses on the data that sits behind leverage, including exposures, financing arrangements, collateral positions, and counterparty relationships. The objective is to provide supervisors with a more meaningful understanding of where risks originate and how they are concentrated.

This reflects a broader theme running throughout the consultation. Rather than receiving increasingly complex regulatory calculations, the FCA is seeking access to the underlying information it can use directly for supervisory purposes.

For firms, this means implementation challenges are likely to be driven less by methodology and more by data availability, governance, and reporting infrastructure.

Operational impact of CP26/26

Although much attention has focused on the reporting templates themselves, CP26/26 goes further than periodic reporting obligations.

The FCA is also proposing changes to authorisation, registration, and change processes, including enhanced information on delegation arrangements and wider use of Legal Entity Identifiers (LEIs) for managers, funds, depositaries, and certain delegates. These proposals could have operational implications independent of the reporting framework itself.

The consultation also formalises when new funds should begin reporting, introducing a clearer trigger linked to the first acceptance of external capital or the first investment decision taken on behalf of a fund.

FRAME is ultimately a data governance exercise

Viewed through a wider lens, FRAME is as much a data initiative as a reporting initiative.

The consultation repeatedly emphasises consistency, comparability, and supervisory usefulness. The FCA is seeking direct access to underlying portfolio, investor, liquidity, and financing data rather than relying on calculated regulatory measures. Firms with mature data governance frameworks and well-understood reporting processes are therefore likely to be in a stronger position than those approaching FRAME purely as a compliance exercise.

Looking ahead

CP26/26 remains a consultation, with responses due by 22 September 2026. The FCA expects to publish final rules during 2027, with implementation taking place in stages before full adoption of the regime in 2028. Further reporting prototypes, Extensible Markup Language (XML) schemas, and technical guidance are expected before then.

While the detail will continue to evolve, firms should not wait for the final rules before beginning their assessments. Understanding the extent to which the existing Annex IV, investor reporting, and risk reporting processes align to FRAME will help identify potential gaps and avoid unnecessary rework later.

At Buzzacott, we are actively monitoring developments as the consultation progresses and engaging with industry feedback. Our focus is helping firms transition from Annex IV to FRAME efficiently, leveraging existing reporting processes and data sources wherever possible rather than reinventing the wheel.

In our next insight, we examine the proposed reporting template itself and explore what Enhanced Reporting could mean in practice for larger and more complex funds. Visit our series hub to find detailed analysis of the latest consultation papers and what they could mean for your firm.