More F(R)AME for UK Alternative Investment Fund Managers

What changes

FRAME brings AIFs, UK UCITS and further fund types into a single framework, calibrated by fund size: funds below GBP 500 million NAV report the essential dataset, funds above it the more extensive enhanced dataset. The FCA expects around 9 % of funds in scope to sit above the threshold. Of the 21,684 AIFs it currently receives reporting on, 19,571 – 90 % – would report essential requirements only.

For threshold changes, the consultation provides two easements that are easily overlooked in planning: an opt-up, allowing firms to report all funds under the enhanced requirements voluntarily, and a time cushion of two quarters or one year before a fund actually has to switch after crossing the threshold.

The scope extends beyond AIFMs: UK UCITS, third-country AIFs marketed under the NPPR, funds recognised under the OFR or Section 272 FSMA and – frequently overlooked – certain MiFID portfolio managers and advisers as well as operators of collective investment schemes. These two groups report nothing today; what is proposed for them is a short annual return, not the full FRAME dataset. For schemes recognised under the OFR or Section 272, essential reporting only is envisaged.

What can already be tested today

The FCA has published three reporting templates – for FRAME, for collective investment schemes and for managers and advisers of segregated mandates – and additionally provides the essential requirements as an online form that firms can test voluntarily. Further prototypes are expected by the end of 2026.

That makes the gap analysis a task for the coming weeks rather than for 2027: map existing reporting outputs field by field against the templates, mark matches and gaps, and carry the open points into your consultation response. Following an extension, responses to the FRAME consultation can now be submitted until 22 October 2026. The consultation period for CP26/28 also closes on 22 October 2026. However, the deadline for most of the topics covered in its discussion chapters remains 18 September 2026.

Where the data breaks

Four areas consistently surface first in the mapping exercise:

• Holdings and identifiers: For the first time, the FCA intends to collect holdings for certain UK authorised funds – under the proposed rules from UK UCITS and NURS above GBP 500 million NAV. For smaller funds it is exploring whether the data can be extracted from annual and interim reports already submitted, noting itself that identifiers such as ISINs are not mandatory there. Firms sourcing holdings from such data should solve identification early.
• Aggregate leverage: A single aggregate leverage and financing table is proposed – borrowing, secured financing, repo, prime brokerage and derivatives – broken down by remaining maturity. Annex IV today provides only a single total and a percentage maturity split, without clearly separating drawn from available financing.
• Value-at-risk: VaR is not only an enhanced topic: it already sits in the essential dataset for UK UCITS that use VaR to calculate global exposure. Counterparty exposure likewise forms part of the essential dataset wherever a fund uses leverage for investment purposes or is a hedge fund.
• Fund profile and strategy: The FCA intends to work largely with multiple-choice options here and to reconcile the answers against data from the fund authorisations gateway. Free-text strategy descriptions from existing reporting do not map onto that without rework.

There is also a structural constraint: holdings are reported at fund rather than share-class level. Share-class-specific exposures such as FX hedging derivatives are therefore not fully captured – relevant wherever the same data is meant to serve frameworks requiring share-class transparency, for example fund look-through reporting under Solvency II. In none of these cases does the effort lie in the form itself, but in the data supply behind it.

Why 2027 is the decisive year

FRAME is targeted for full implementation in 2028, with individual elements possibly earlier. The date that matters for planning, however, is a different one: the FCA’s final policy statement is expected in the first half of 2027 – and in the same period ESMA must deliver the new RTS and ITS for AIFMD II reporting, with a deadline of 16 April 2027.

Decisions on data model and architecture therefore fall in the same year in both jurisdictions. For firms operating across borders, that is the actual planning point: the EU is not removing Annex IV but extending it – AIFMD II and the associated amandments to the UCITS Directive (UCITS VI) have applied since 16 April 2026 with expanded reporting obligations, and the forthcoming technical standards will reshape the templates again. The UK and the EU are moving at the same time, but in different directions.

The FCA building its sub-asset classes on existing AIFMD categories where possible keeps reuse of the underlying portfolio, reference and risk data practicable. The reporting formats will differ; the data basis does not have to. Around eighteen months are enough to master that data properly once – but not if you start only after the final rules are published.

Key dates

• 14 July 2026: FCA publishes CP26/26 (FRAME) and CP26/28; reporting templates and online test form available
• 18 September 2026: Discussion chapters in CP26/28 close
• 22 October 2026: FRAME consultation closes
• 22 October 2026: CP26/28 consultation closes
• By end-2026: Further prototype reporting forms for industry testing
• H1 2027: FCA final policy statement expected
• 16 April 2027: Deadline for ESMA to deliver the RTS/ITS for AIFMD II reporting
• 2028: Targeted full implementation of FRAME

What to do now

• Define scope: Which entities and funds fall under FRAME, which sit above or close to the GBP 500 million threshold – and is an opt-up worthwhile to run a single consistent dataset?
• Map the templates: Compare existing reporting outputs field by field against FRAME and document the gaps.
• Take part in the FCA testing: Use the online form and the prototypes, and feed the findings into your consultation response by 22 September 2026.
• Plan the UK and the EU together: Make the data model decisions for FRAME and for AIFMD II or future UCITS reporting in one go, not sequentially.

Would you like to discuss what FRAME, AIFMD II or UCITS VI mean for your reporting, your data architecture or your implementation planning? Please get in touch.