CITIC Securities | Interpretation of Private Fund Information Disclosure Rules

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Text | Yao Ziwei, Sun Shiyu, Ying Shaohua, Miao Jinjing

The China Securities Investment Fund Association recently organized the drafting of the “Implementation Rules for Private Fund Information Disclosure (Draft for Comments),” which mainly includes: refining the requirements for regular reports of securities and equity funds, setting mandatory audit quantitative standards; clarifying details on transparent disclosure, related-party transactions, and liquidation disclosures; promoting standardized content templates and backup platforms; and strengthening self-regulation measures such as conversations, warnings, and disciplinary actions. This week, the performance of cyclical sector funds led, with an average decline of 0.48% over the past week. Fund positions slightly increased this week, remaining at a medium level over the past year. In terms of style, many funds increased holdings in small-cap growth stocks, with an industry tilt toward automotive. Fund issuance activity this week is at a high level in nearly two years, mainly index funds.

Hotspot Analysis

The China Securities Investment Fund Association recently organized the drafting of the “Implementation Rules for Private Fund Information Disclosure (Draft for Comments),” marking a shift from “self-regulation-led” private fund disclosure to a “rigid regulatory stage of administrative and self-regulation collaboration.” The core content includes: refining the disclosure requirements for securities and equity funds, setting mandatory audit standards; clarifying details on transparent disclosure, related-party transactions, and liquidation disclosures; promoting standardized content templates and backup platforms; and strengthening self-regulation measures such as conversations, warnings, and disciplinary actions.

Market Tracking

This week (20260309-20260313), the CSI 300 rose by 0.19%, the Hang Seng Tech Index increased by 0.62%, with large-cap growth outperforming small-cap growth. In sectors, coal performed best, along with construction, electrical equipment and new energy, power and utilities; defense military, petrochemical, comprehensive finance, non-ferrous metals, and media performed relatively poorly. Cyclical sector funds outperformed, with an average decline of 0.48% over the past week. As of March 13, the average stock fund position slightly increased, with total positions at a medium level over the past year. Style-wise, funds increased holdings in small-cap growth and automotive sectors, while reducing positions in pharmaceuticals, biologicals, and electronics.

Market Dynamics

Industry News: CSRC issued new regulations on public fund disclosure; new public fund products frequently close fundraising early; southbound funds hit record levels in bottom-fishing Hong Kong stocks; since the beginning of the year, public funds’ self-purchase amounts exceeded 900 million yuan; banks are actively increasing capital.

Product Hotspots: Another AI ETF is about to launch on the Hong Kong Stock Exchange; E Fund Ruyi Yingze 6-month holding period FOF sold out in one day; funds continue to flow into semiconductor-themed ETFs.

Overseas Market Tracking: Major foreign fund giants are increasing their holdings of Chinese stocks; BlackRock restricts redemptions of its private credit funds.

Institutional Movements

This week, Puyin Ansheng Fund and ICBC Credit Suisse Fund experienced management changes.

New Market

Fund issuance activity this week remains at a high level in nearly two years, mainly index funds.

Hotspot Analysis

1.1 Interpretation of the Private Fund Information Disclosure Rules

1.1.1 Main Content of the Private Fund Information Disclosure Rules

As of the end of January 2026, there are 19,000 existing private fund managers managing 139,000 funds with a total scale of 22.4 trillion yuan. Private funds have become important participants in the capital market and even the real economy.

In 2025, private funds issued 25,500 funds with a total scale of 331.232 billion yuan. However, 21,600 funds were liquidated, with 214 liquidations in January 2026. For a long time, the regulatory rules related to private fund disclosure have had three major structural flaws:

• Low hierarchy: Administrative regulations mainly follow the “Interim Measures for the Supervision and Administration of Private Investment Funds,” which are principle-based;
• Fragmented rules: Specific regulatory requirements are mainly based on self-regulation rules of the Fund Industry Association, lacking dedicated administrative regulations;
• Lack of transparency: Insufficient requirements for transparent disclosure, leading to long-standing issues where investors cannot see through nested investments.

Recently, the CSRC issued the “Supervision and Management Measures for Private Fund Information Disclosure” (hereinafter referred to as the “Disclosure Measures”). To implement these requirements, the China Securities Investment Fund Industry Association (hereinafter referred to as the “Association”) organized the drafting of the “Implementation Rules for Private Fund Information Disclosure (Draft for Comments)” (hereinafter “Disclosure Rules”) and the “Key Content Template for Private Fund Information Disclosure (Draft for Comments)” (hereinafter “Key Content Template”). These documents are now open for public comment.

Specifically, the “Disclosure Rules” consist of seven chapters and fifty-one articles, mainly including:

First, refining the disclosure requirements for regular reports of private securities funds. This includes detailed requirements for net asset value disclosures, financial status, leverage levels, related-party transactions, and cross-border investments in the “Information Disclosure Measures.” It further clarifies the requirements for transparent disclosure of direct investments and nested assets, including the top ten underlying investments and full investment paths. For assets exceeding certain proportions of the fund’s net assets, specific information must be disclosed. Cross-border investment disclosures are also detailed. The audit standards for “main investment directions” are clarified, requiring annual financial reports to be audited by qualified accounting firms if the fund’s assets in certain categories exceed 60% of net assets.

Second, refining the disclosure requirements for private equity funds’ regular reports. This includes detailed disclosures of net assets, leverage, related-party transactions, and underlying investments. It clarifies the disclosure of investment targets, including transparent disclosure of nested investments, with the top ten investments and full investment paths. The audit standards specify that funds with a management scale over 100 million yuan and more than 20 natural persons as investors must have their annual financial reports audited by qualified firms.

Third, clarifying the disclosure requirements for interim and liquidation reports. Interim reports must disclose major related-party transactions, including related party names, relationships, transaction details, prices, amounts, pricing basis, and transaction summaries. Liquidation disclosures are detailed, requiring interim disclosures if liquidation cannot be completed within the planned period, and continuous disclosure before complete liquidation.

Fourth, establishing templates for disclosure content and backup requirements. Managers must disclose information according to the “Key Content Template,” with flexible formatting. Disclosed content must be backed up on the designated platform of the CSRC, which is not a disclosure channel but a storage platform for regulatory review. The Association will keep backup data confidential, except for legal investigations. Text requirements, confidentiality, and management are specified.

Fifth, strengthening self-regulation. The Association can take measures such as conversations, written warnings, and corrective deadlines, as well as disciplinary actions like warnings, public criticism, and restrictions on business activities, based on laws, regulations, and self-regulation rules.

1.1.2 Characteristics of the Disclosure Rules

Compared with the “Supervision and Management Measures for Private Fund Information Disclosure,” the “Disclosure Rules” deepen the regulatory logic along three dimensions:

In regulatory constraints, moving from “qualitative guidance” to “quantitative rigidity.” Setting a 60% red line for securities assets and a threshold of “100 million yuan/20 natural persons” for equity assets eliminates ambiguity in enforcement.

In transparency depth, shifting from “result correlation” to “full-path tracing.” Requiring disclosure of underlying investments and investment paths, including the top ten investments, to fully penetrate multi-layer structures.

In management model, moving from “manager discretion” to “standardized templates.” Establishing a firm bottom line with the “Key Content Template” and strengthening traceability through designated backup platforms.

The disclosure checklist for private funds features “categorical policies, underlying transparency, and quantitative regulation.” For private securities funds, the list emphasizes real-time monitoring of liquidity and market risks, including derivatives leverage, cross-border investment paths, and high-concentration targets. For private equity and venture capital funds, the focus shifts to transparency of underlying assets, project ownership, investment structure, and SPV liabilities, with metrics like DPI and TVPI to show returns. This differentiated design clarifies previous ambiguities like “main investment directions” and ensures standardized, serious disclosures through templates and quantitative audit standards (e.g., 60% asset ratio or 100 million yuan threshold). Overall, the checklist aims to build a closed-loop system from self-regulation by managers to investor supervision, marking a move toward higher transparency and traceability in the private fund industry.

The issuance of the “Supervision and Management Measures for Private Fund Information Disclosure” and the accompanying “Implementation Rules” signifies a transition from “self-regulation-led” disclosure to a “rigid regulatory stage of combined administrative and self-regulation” constraints.

Core changes include: first, elevated regulatory level, filling the regulatory gap with formal CSRC regulations; second, extended responsibility chain, adding sales agencies as obligated entities and including managers’ shareholders, partners, and actual controllers; third, strengthened transparency of nested investments, requiring disclosure of investment paths and underlying assets, solving the long-standing “opaque” problem; fourth, differentiated arrangements, with quarterly disclosures for securities funds, semi-annual for equity funds, and annual for venture capital funds, reducing compliance burdens for non-standard products; fifth, increased penalties, with fines up to 1 million yuan or five times illegal gains, shifting from “soft constraints” to “hard constraints.” The new regulations will take effect on September 1, 2026, likely accelerating industry淘汰 and promoting a “good money drives out bad.”

1.1.3 Impact of the Private Fund Disclosure Rules on the Industry

For private fund managers, compliance ability becomes a core competitive advantage. Before implementation, managers face short-term pressures: increased compliance costs, significant operational burdens from transparent disclosures and mandatory audits, especially for small and medium institutions needing system upgrades. They must establish sound disclosure management systems and improve shareholder/partner cooperation mechanisms. In the medium to long term, industry segmentation will accelerate: as of March 6, 2026, 140 private fund managers have deregistered this year, including 92 voluntary deregistrations. Leading institutions can leverage compliance advantages to enhance brand value and consolidate market position; poorly regulated or risk-weak firms will be phased out faster. The “good money drives out bad” effect is expected to emerge, fostering a positive competitive environment.

For investors, the right to know is substantively enhanced. Transparent disclosures allow investors to understand ultimate fund allocations, alleviating information asymmetry; mandatory audits provide independent verification of financial data; ongoing disclosures during liquidation eliminate information gaps; and the backup platform enables investors to query disclosures proactively.

For regulatory authorities, the focus shifts from “pre-entry” to “continuous supervision.” The core mechanism changes from a “front-end approval” to a “dual system of ongoing regulation,” establishing a formal “administrative + self-regulation” framework. The CSRC and its local offices can issue corrective orders, regulatory conversations, and warning letters; the Association can take self-regulation measures such as reminders, warnings, and deadlines, with serious cases facing warnings, public criticism, and restrictions on activities.

This report is for investment reference only. Past performance does not predict future results and does not guarantee returns or constitute investment advice. Some materials are compiled from public news reports and may contain inaccuracies. Data from third-party databases vary in update frequency; completeness and timing may affect accuracy. Fund position estimates are based on models with assumptions, which may not fully reflect actual conditions, leading to potential deviations. Data sources may have minor missing values, slightly increasing statistical errors. Historical data interval choices also influence results.

Research Report Title: “Interpretation of Private Fund Information Disclosure Rules”

Publication Date: March 15, 2026

Published by: CITIC Securities Co., Ltd.

Analysts:

Yao Ziwei SAC No.: S1440524040001

Sun Shiyu SAC No.: S1440524060007

Ying Shaohua SAC No.: S1440525060001

Miao Jinjing SAC No.: S1440525080003

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