The FCA’s FRAME consultation, originally due to close on 22 September 2026, has been extended to 22 October 2026. FRAME (consultation paper CP26/26) would replace today’s patchwork of fund returns, forms and notifications, including the AIFMD annex IV return, with a single reporting framework for almost every fund managed or marketed in the UK. If you had a response half written, or hadn’t started one, this is the extra runway.
What FRAME is
FRAME (CP26/26, published July 2026) is the FCA’s proposal for a single fund reporting framework, calibrated to the type, size and activity of each fund. It is one of three consultation papers in the FCA’s asset management reform package, alongside the rewrite of the UK AIFM regime, and it carries three design principles: simplicity, proportionality and international alignment.
It is broad. In scope are FCA-authorised UK AIFMs and every AIF they manage, UK UCITS management companies, managers of registered venture capital and social entrepreneurship funds, third-country AIFMs marketing under the national private placement regime, and operators of recognised overseas schemes under the Overseas Funds Regime and section 272. The FCA’s own analysis covers roughly 32,000 funds and around 6,500 firms.
What would change
Two tiers, set by fund size. Every fund would submit a set of “essential” data. Funds at or above £500 million net asset value would add a more extensive “enhanced” set covering strategy, dealing terms, investor base, fees and flows, concentrations, liquidity and stress sensitivities. The threshold sits at fund level, not manager level, so a large manager still reports essential data for its smaller funds. The FCA estimates around 9% of in-scope funds would fall into the enhanced tier. Firms could opt smaller funds up to enhanced reporting for consistency, and a two-quarter cushion would apply before a fund that crosses the threshold has to meet the higher tier.
Frequency and lag driven by liquidity. Daily-dealing funds such as UK UCITS, NURS and QIS would report quarterly with a 30-day lag. Semi-liquid funds such as LTAFs would report quarterly with a 60-day lag. The least liquid private market funds would report annually with a 120-day lag. Hedge funds would report quarterly with a 45-day lag, plus event-based reporting for funds above £500 million that suffer a 10% drawdown. The FCA says lags are maintained or extended for every fund type, and that thousands of funds would move from four filings a year to one.
Holdings data for retail funds, for the first time. The FCA proposes collecting fund-level holdings from UK UCITS and NURS as at the last business day of each reporting period, giving it a direct view of portfolio composition. This is the single biggest new data ask for authorised fund managers.
What is annex IV reporting, and how does FRAME change it?
Annex IV reporting is the AIFMD transparency return that in-scope UK AIFMs file today, using the forms AIF001 and AIF002. It sits alongside FSA042, a separate UCITS derivatives return that isn’t part of the AIFMD annex IV framework at all. FRAME would retire all three: AIF001, AIF002 and FSA042, and replace them with the essential and enhanced datasets described above. For an AIFM that currently produces annex IV reporting, that’s a change in data model, not just a new form to complete.
The FCA is also asking whether the Consumer Composite Investments product summary filing rule (DISC 3.5.1R) should go, since FRAME would capture the same information periodically.
New reporting for firms that report little today
MiFID investment managers and advisers would file a short annual return covering derivatives, borrowings, funds under management and assets under advice. Around 400 firms holding collective investment scheme operator permissions would file a short annual operator-level return. Overseas Funds Regime and section 272 recognised schemes would move to reporting limited data on a periodic basis, though the exact frequency is one to confirm against the consultation paper directly before quoting it.
What it means in practice
The FCA expects FRAME to bring ongoing savings of around £147.8 million a year for AIFMs. The other side of the ledger matters too: around £139.8 million in one-off implementation costs across all firms, and roughly £19.6 million a year in new ongoing costs for UCITS managers, driven mainly by holdings reporting.
So the net effect depends on what you run. Managers of unauthorised AIFs below £500 million should see their reporting shrink. Managers of UK UCITS and NURS, and firms in the enhanced tier, are looking at a new data pipeline: sourcing, validating and submitting holdings and portfolio data on a quarterly cycle, and linking it consistently to fund reference data through legal entity identifiers and share-class identifiers.
That’s a data governance project as much as a compliance one. The fields the FCA wants are the same fields that feed factsheets, product summaries, annual reports and investor portals, so firms that already produce those outputs from one governed dataset will be able to answer FRAME from the same source. Firms that don’t will be building it twice.
The timeline
- 22 October 2026: consultation closes. Responses go through the FCA’s online form or to [email protected].
- Before the end of 2026: the FCA has committed to further prototype forms for voluntary testing, on top of the essential-requirements prototype and three Excel reporting templates already published with the CP.
- First half of 2027: policy statement with final rules.
- Before the end of 2027: the FCA is considering introducing essential reporting for funds under £500 million early.
- 2028: full implementation. The FCA has asked respondents how much lead time they need between final rules and go-live, which is worth answering carefully rather than leaving silent.
What to do this week
- Map your funds to the tiers: which are above £500 million NAV, which are hedge, private market, LTAF or authorised retail, and what frequency and lag each would attract.
- Test the prototype: the essential-requirements form is live for voluntary testing, and the templates show every proposed field. Trace each one back to where the data lives today.
- Respond on the questions that affect you: the consultation covers the threshold, the holdings requirement, the retirement of the product summary filing rule and the implementation lead time. Silence on lead time in particular is likely to be read as agreement.
FRAME is still a proposal, not law, and the final rules will move. But the direction is settled: fewer forms, more structured data, and a regulator that expects the same numbers to reconcile across everything a fund publishes. An extra month is a gift. Spend it on the questions that matter to you.
This is exactly the kind of change we spend our time on with clients: tracing every field a regulator asks for back to a single governed dataset, so annex IV reporting, holdings data and everything else FRAME asks for comes from the same source as your factsheets, client reports and investor portals. If you’d like a second pair of eyes on your fund-to-tier mapping, get in touch.
Sources: FCA CP26/26 landing page (deadline extension recorded 27 August 2026) and the CP26/26 PDF, chapters 1, 3, 5, 7, 8 and Annex 2, checked 21 September 2026.
