New Private Fund Disclosure Rules Seek Public Comment, Strengthening Penetrating Disclosure to Ensure Authenticity

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Reporter Wei Shuguang from Securities Times

On March 13, the Asset Management Association of China released the “Implementation Rules for Private Fund Information Disclosure (Draft for Comments)” and the “Template for Key Content of Private Fund Information Disclosure (Draft for Comments),” publicly soliciting opinions from society. The purpose of this revision is to implement the “Measures for Supervision and Administration of Private Fund Information Disclosure” by the China Securities Regulatory Commission, through refining disclosure standards, strengthening transparency requirements, and improving self-regulatory mechanisms, to promote standardized development of the private fund industry and effectively protect investors’ legitimate rights and interests.

The new regulations specify differentiated and detailed disclosure requirements for regular reports of private securities funds and private equity funds. Private securities funds must clarify details such as net value, financial status, leverage levels, related-party transactions, cross-border investments, etc. For nested investments, disclosure must include the asset categories, amounts, and proportions calculated through transparency after consolidation; assets exceeding a certain proportion of net assets must be disclosed separately. For cross-border investments, disclosure of scale, methods, and pathways is required. The standards for auditing are also clarified: if the proportion of assets with liquidity restrictions at the end of the quarter, New Third Board stocks, off-exchange derivatives, overseas assets, and other private funds managed by other managers exceeds 60% individually or in total, the annual report must be audited by a certified public accounting firm in accordance with the Securities Law.

Private equity funds focus on disclosures related to net assets, leverage, related-party transactions, etc. Investment projects must specify the industry, amount, exit method, and structure. Nested investments require transparency of the top ten projects before disclosure. For funds with a scale exceeding 100 million yuan and more than 20 individual investors, the annual report must also be audited to ensure the authenticity and reliability of the information.

For interim reports, significant related-party transactions must disclose related parties, transaction prices, amounts, and pricing basis; liquidation reports require that if liquidation cannot be completed on time, they must be disclosed temporarily before the scheduled deadline, emphasizing continuous disclosure according to regular reporting requirements before liquidation to avoid information gaps.

The association also simultaneously developed templates for key content of information disclosure, clarifying that managers’ disclosures should meet or exceed the template requirements, with flexible formats to reflect the characteristics of private funds. It also specifies requirements for the backup platform for information disclosure: managers must back up data on the platform designated by the CSRC, investors can log in to query, and the platform information is strictly confidential, used only for regulatory cooperation in case of investigations or inquiries. Additionally, the new regulations detail text management and confidentiality requirements to ensure standardized and orderly disclosure.

The association will, in accordance with laws, regulations, and self-regulatory rules, oversee the disclosure behaviors of managers, custodians, sales institutions, service agencies, and their staff. Self-regulatory measures such as interviews, written warnings, and deadlines for correction may be taken; in serious cases, disciplinary actions including warnings, public reprimands, and restrictions on business activities will be imposed to create an effective deterrent.

The new regulations are scheduled to take effect on September 1, 2026, with the old measures issued in 2016 being repealed simultaneously. Considering the need for market participants to upgrade systems and improve disclosure documents, the association will further refine the regulations based on feedback and release them as soon as possible. It will also comprehensively upgrade the private fund information disclosure backup system, with the specific launch date to be announced separately.

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责任编辑：Shi Xiuzhen SF183