Converting Principled Regulations into Executable, Verifiable, and Accountable Concrete Standards: 2.2 Trillion Yuan Private Equity Market Welcomes Information Disclosure "Operating Manual"

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Special Topic: China Securities Regulatory Commission Releases “Measures for Supervision and Administration of Private Fund Information Disclosure”

◎ Reporter Liang Yinyan

The first administrative regulation on private fund information disclosure was released just two weeks ago. The supporting detailed operation manual—the “Implementation Rules for Private Fund Information Disclosure (Draft for Comments)” (hereinafter referred to as “Implementation Rules”) and the “Template for Key Content of Private Fund Information Disclosure (Draft for Comments)” (hereinafter referred to as “Key Content Template”)—has recently solicited public opinions. This marks that the information disclosure regulation for the private market of 22.4 trillion yuan is moving from institutional design to practical implementation.

Industry insiders believe that the Implementation Rules and Key Content Template further improve the self-regulatory framework for private investment funds. After official release, a system of “departmental regulations + normative documents + self-regulatory rules” for private fund information disclosure will be formed. This “Rules + Templates” combination transforms high-level regulations into concrete standards that are actionable, verifiable, and accountable, providing private fund managers with a clear “operation manual” and “compliance guide.”

The “1+N+X” System Continues to Improve

On March 13, the Asset Management Association of China (AMAC) released the Implementation Rules and the supporting Key Content Template for public consultation. This is the first detailed self-regulatory rule released after the China Securities Regulatory Commission (CSRC) issued the “Measures for Supervision and Administration of Private Fund Information Disclosure” (hereinafter referred to as “Disclosure Measures”) on February 27.

Guotai Haitong Securities officials told Shanghai Securities News that the Implementation Rules and Key Content Template effectively connect with the Disclosure Measures, further detailing the requirements for private fund information disclosure. They help clarify the responsibilities of industry participants, improve the standardization and transparency of private fund disclosures, and lay a solid institutional foundation for the high-quality development of the private fund industry.

“Implementation Rules translate the requirements of the Disclosure Measures into clearer execution standards and operational checklists, focusing on core aspects such as periodic reports, interim reports, and liquidation reports. They specify quantitative details for disclosures like transparency, cross-border investments, and significant related-party transactions, ensuring the practical implementation of the Disclosure Measures at the industry level,” said a senior executive from Fresh Capital Investment to Shanghai Securities News.

A senior official from the CSRC previously stated that for private funds, the “1+N+X” system should be improved, with sound rules covering access, fundraising, custody, and disclosure, and strict crackdowns on illegal activities such as illegal fundraising, misappropriation, self-dealing, and利益输送, promoting industry regulation and development.

Li Shoushuang, managing partner at Dacheng Law Firm, told Shanghai Securities News that 2026 is expected to mark a new starting point for the upgrading of regulations and supervision rules for the private fund industry. As the “1+N+X” system continues to improve, the industry will see a more three-dimensional, standardized, and comprehensive legal environment.

Ensuring Information Disclosure is “Seen and Can Be Checked”

According to the Implementation Rules and Key Content Template, managers must disclose information to investors that meets or exceeds the requirements of the key content template. The specific format can be customized to reflect the characteristics of private funds.

“The changes in the disclosure templates are significant, with a noticeable increase in new content,” said a senior executive from Fresh Capital Investment. “Standardized disclosure helps upgrade transparency in private fund operations.” Managers are allowed to customize formats based on product features, ensuring core information is standardized and readable while maintaining flexibility for fund strategies. The templates embed mandatory disclosures such as transparency and risk warnings, pushing managers to improve internal controls and compliance awareness, and promoting a shift toward “proactive transparency” in the industry.

Additionally, private fund managers are required to back up the disclosed information on the CSRC-designated information disclosure backup platform. The backup platform does not serve as a disclosure channel; it only stores backups. If information not disclosed through other channels is stored there, it is considered a failure to fulfill disclosure obligations.

According to a senior executive from Shenzhen Capital Group, standardized and clear disclosure standards will promote a more effective market filtering mechanism, encouraging resources to flow toward well-regulated, transparent institutions, alleviating the “bad money drives out good” problem from a systemic perspective.

A senior official from Chongyang Investment told Shanghai Securities News that the Implementation Rules establish a dual-track system of “active disclosure via designated channels + passive archiving on backup platforms.” Active disclosure ensures timely, convenient, and effective information sharing, while passive archiving guarantees verifiability and traceability. This ensures information is both “seen” and “can be checked,” pushing fund managers from merely “meeting regulatory requirements” to “serving clients,” fully protecting investors’ right to know.

Promoting Industry Transformation and Upgrading

The Disclosure Measures and Implementation Rules systematically cover the entire private fund operation process, including the shortcoming of information disclosure during liquidation, safeguarding investors’ full-process right to know. They also grant clearer self-regulatory authority to AMAC, significantly increasing the costs of illegal activities such as violations and misconduct.

Guotou Chuanghe Fund officials told Shanghai Securities News that this revision not only provides clearer rules for fund managers but also clarifies the implementation measures for self-regulation by AMAC. This benefits the protection of investors’ legitimate rights and interests and enhances the professional operation capabilities of private fund management institutions, helping private funds operate transparently and gain investor trust.

“Implementation of the Disclosure Measures and Implementation Rules will promote the industry’s move toward standardization, transparency, and regulation,” said a senior executive from Hei Yi Investment. “Refined disclosure requirements and unified templates will effectively address information asymmetry, helping investors fully understand fund operations, risks, and performance. It will also push managers to improve internal controls, enhance disclosure quality, and standardize investment practices. Institutions with poor disclosure and weak risk controls will gradually be phased out, supporting the ‘good money drives out bad’ goal.”