The FCA proposes to rebuild the UK AIFM regime

Nothing here binds anybody yet. CP26/28 is a consultation paper, and its discussion chapters carry response dates earlier than the consultation's own, so a firm reading it has more than one deadline during September and October 2026. The FCA intends to consult again with draft rules on the areas this paper leaves open. Everything after that is indicative: final rules are expected during 2027, once HM Treasury's statutory instrument is made, and the implementation date currently envisaged for the new regime is 2028. A threshold consulted on in July 2026 is a figure the FCA has asked the market about. It is not a figure to build a plan on. The useful work now is to establish where the firm would fall, and what it would owe if the proposals were adopted as drafted.

A move from assets under management to net asset value is not a relabelling. It changes the basis of measurement, and with it the answer for firms whose funds borrow, that manage committed but undrawn capital, or that run several vehicles of different sizes under one authorised entity. A house with one manager and one fund can work this out in an afternoon. A house with four regulated firms, twenty vehicles and a history of acquisitions cannot.

The questions the proposals put to a manager are narrow and answerable. Which legal entities hold an FCA permission, and which permission is it. Which of them is full-scope, which sub-threshold, which registered and under which registration. Which funds does each one actually manage, and what is the net asset value of each. A group that answers those from a spreadsheet one person maintains cannot size the impact of a consultation before it closes.

Permissions are a property of the legal entity, and a register of them is a small thing to keep. For each regulated firm: the registered name, the firm reference number, the permissions held, the current classification under the existing regime, the funds managed and the individuals holding senior management functions. Where a permission was varied, keep the document and the date it took effect. That register earns its keep beyond this consultation. It is what a response to the FCA is drafted from, what an authorisation application is assembled from if the registration route closes for a firm, and what an investor's operational due diligence asks for anyway. It also has a property no plan has: it is true on the day it is read, whatever the final rules turn out to say.

Alethia holds each regulated firm and each fund as an entity, with its ownership, its officers, its documents and the mandates over its bank accounts. Authorisation documents, permission notices and appointment letters are attached to the entity they belong to, so which company holds which permission has a documented answer and a date beside it.

Ownership and management relationships between those entities are recorded and drawn as a structure chart from the same data, and reports show what is held where. The consultation work itself can be carried as a compliance obligation with an owner and a due date against the firm it concerns. The net asset value calculation stays where it is done, and nothing goes to the FCA from here. What changes is the Monday in September when the response is being drafted: the list of firms, permissions and funds is already on the screen, and the argument can be about the proposals.