On 14 July 2026, the FCA published CP26/26, introducing the proposed Fund Reporting for Asset Management Entities (FRAME) framework. While much of the initial discussion has focused on the volume of new reporting requirements, the most significant development may be the FCA’s decision to move away from the existing UK Annex IV reporting framework that has underpinned regulatory reporting for UK AIFMs for more than a decade.
For UK fund managers, this is more than a simple reporting update. FCA FRAME reporting represents a fundamental redesign of how UK regulators intend to collect information from investment funds, extending reporting requirements beyond AIFs and introducing a single framework covering a much broader range of fund structures.
What Is the FCA FRAME Framework? (Replacing UK Annex IV)
The FCA is proposing to replace the current UK Annex IV reporting framework with a standardised reporting regime centred around the new FRAME reporting template. The proposals extend reporting obligations across both AIFs and certain non-AIF collective investment schemes, including UK UCITS.
Key Datasets Required Under the New Template
The proposals introduce new datasets covering areas such as:
- Liquidity Management Tools (LMTs)
- Counterparty exposure and borrowing
- Fund marketing jurisdictions
- Share class reporting
- Benchmark reporting
- Detailed holdings information
- Expanded investor and financing data
For managers currently reporting under UK Annex IV, the breadth of the proposed reporting represents a significant expansion in both scope and data requirements.
Essential vs. Enhanced: Navigating the New FCA FRAME Reporting Requirements
One of the most notable aspects of the proposed framework is the introduction of two reporting layers.
The Essential Requirements contain 58 questions and are intended for smaller funds. The Enhanced Requirements add a further 250 questions covering more detailed portfolio, exposure and risk information. The current proposal uses a fund NAV threshold of €500 million to determine which reporting requirements apply.
This approach is intended to create a more proportionate reporting model while still allowing the FCA to collect significantly more granular information from larger funds and managers.
The Impact of CP26/26 on UK UCITS Managers
Perhaps the biggest surprise within the consultation is the extent to which UCITS managers will become subject to detailed reporting requirements.
The FCA is proposing additional disclosures covering share classes, benchmarks, holdings, subscriptions and redemptions, together with various fund-level metrics that historically have not formed part of UK UCITS reporting requirements.
For many firms, particularly those operating UCITS structures, data sourcing and operational readiness may prove just as challenging as the reporting itself.
Implementation Timeline for the FCA FRAME Reporting Overhaul
While final rules are not expected until 2027, the consultation period remains open until October 2026 and additional prototype templates are expected before the end of the year. Full implementation is currently anticipated during 2028.
This means firms have an opportunity to assess potential impacts, identify data gaps and prepare for what could become the most significant UK fund reporting change since the introduction of Annex IV reporting.
Download Our FCA FRAME Briefing Paper
Funds-Axis has produced a detailed briefing exploring:
- The proposed FRAME reporting templates
- Essential and Enhanced reporting requirements
- Reporting frequencies and submission timelines
- Key differences from Annex IV reporting
- What fund managers should be doing now
Download the full FCA FRAME Reporting Framework briefing paper to understand how the proposals may affect your reporting obligations and operational processes.
