UK Unveils Sweeping Rewrite of AIFM Regime With Three-Tier Classification and FRAME
HM Treasury and the FCA have opened a coordinated consultation repealing the 2013 AIFM Regulations, replacing Annex IV with FRAME, and tiering UK managers by NAV, with implementation targeted for 2028.
On 14 July 2026, HM Treasury and the FCA published a coordinated package comprising a draft statutory instrument repealing the AIFM Regulations 2013, FCA Consultation Paper CP26/28 on the new UK AIFM regime, CP26/26 on the FRAME reporting framework, and CP26/27 on consolidating three remuneration codes into a single principles-based regime. The package would create a new Alternative Investment Funds sourcebook (ALTS) within the FCA Handbook and classify UK AIFMs into three tiers by aggregate NAV, with proportionality running through governance, reporting and remuneration requirements. Sophisticated counsel and clients care because the regime reaches well beyond classic UK AIFMs, capturing third-country managers using the UK National Private Placement Regime, MiFID portfolio managers, UCITS management companies and listed closed-ended vehicles, and because UK and EU requirements will increasingly diverge, forcing cross-border groups to run parallel compliance manuals, reporting processes and governance frameworks. FRAME is not a relabeling of Annex IV; it changes scope, thresholds, frequency, event triggers, data fields and submission mechanics. Consultation windows close between 16 September and 14 October 2026, with final policy statements targeted in 2027 and main implementation in 2028; firms should use 2026 to classify entities, map data gaps and prioritize responses.