The FCA is consulting on replacing the full-scope and sub-threshold split with three size tiers based on net asset value, not leveraged assets. Enter your NAV to see which tier CP26/28 would put you in, and how close you are to the next one.
Consulted on in CP26/28, published 14 July 2026. These are proposals, not rules. The consultation closes on 14 October 2026 and the implementation date currently envisaged is 2028.
| Tier | Net asset value | What the FCA says |
|---|---|---|
| Small | Below £750m | Lighter requirements. The FCA originally proposed £100m here, then raised it to £750m after consistent feedback that the lower figure was too low. |
| Medium | £750m to £5bn | The middle of the graduated regime, between the lighter small-firm requirements and full application for large firms. |
| Large | Above £5bn | Most rigorous application. The FCA cites the greater potential market impact of firms at this size. Most respondents agreed with the £5bn level. |
Source: FCA CP26/28: The UK AIFM Regime, paragraphs 2.4 to 2.11. Last reviewed August 2026.
The headline of CP26/28 is the three tiers. The change with more operational consequence is quieter: size is measured on net asset value rather than leveraged assets under management.
That is not a relabelling. A leveraged fund and an unleveraged fund of the same NAV are now treated the same way, where previously they were not. Some managers will find their tier moves relative to their current classification, in both directions. The proposals also remove the full-scope and sub-threshold distinction entirely, so today's categories will not carry over.
There is a second-order effect worth sitting with. When NAV determines your regulatory tier, the NAV figure stops being purely an operational output and becomes a supervisory data point. A firm sitting near £750m or near £5bn has a direct interest in how that number is produced, who reviewed it, and whether the working can be shown on request. That is a different standard from calculating a NAV correctly for dealing purposes, and it is not one a spreadsheet passed around by email answers well.
The FCA also proposes a new Alternative Investment Funds sourcebook, ALTS, to bring most AIFM rules into one place, and has published two companion consultations: CP26/26 on fund reporting (FRAME) and CP26/27 on remuneration.
Small is below £750m NAV, medium is £750m to £5bn, and large is above £5bn. The FCA originally proposed £100m as the small to medium threshold in its Call for Input and raised it to £750m after consistent feedback that the lower figure was too low. The £5bn upper threshold was broadly supported and is unchanged.
Net asset value. CP26/28 moves the size calculation away from leveraged assets under management to a simpler NAV basis. Firms whose current classification reflects leverage should expect their tier to be assessed differently.
Yes. The proposals remove that distinction and replace it with the three NAV-based size categories, with the rules applied in a graduated way across them.
CP26/28 opened on 14 July 2026 and closes on 14 October 2026. The FCA invites responses on the discussion chapters by 18 September 2026, except the chapter on prudential reforms, which also closes on 14 October. A policy statement with final rules will follow, along with a second consultation covering remaining areas.
The implementation date currently envisaged is 2028. The Treasury is running a parallel consultation on the underlying legislation.
A proposed new Alternative Investment Funds sourcebook that would consolidate most AIFM rules in one place, replacing a framework currently spread across legislation, Treasury regulations and FCA rules.
daappa NAV Oversight replaces the manual movement-check spreadsheet with automated tolerance checks, exception-first review, maker-checker sign-off and a full audit trail.