Transforming principles into concrete standards that are actionable, verifiable, and accountable: 22 trillion yuan private equity market welcomes an information disclosure "operation manual"

Log in to Sina Finance App and search for [Information Disclosure] to see more evaluation levels

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

◎ Reporter: Liang Yanyan

Just two weeks after the first administrative regulation on private fund information disclosure was issued, 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”) have recently been open for public comment. This marks that the regulation of information disclosure for the 22.4 trillion yuan private market 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. Once officially released, they will form an information disclosure system comprising “departmental regulations + normative documents + self-regulatory rules.” This “Rules + Templates” combination will turn high-level regulations into specific, actionable, checkable, and accountable standards, 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 enforcement standards and operational checklists, focusing on key aspects such as periodic reports, interim reports, and liquidation reports. They specify quantitative requirements for transparent disclosure, cross-border investments, and major related-party transactions, ensuring the practical implementation of the Disclosure Measures at the industry level,” said a person in charge of Fresh Capital Investment to Shanghai Securities News.

A senior official previously stated that for private funds, improving the “1+N+X” system, and establishing sound rules for access, fundraising, custody, and disclosure, as well as cracking down on illegal activities such as illegal fundraising, misappropriation, self-dealing, and利益输送, will promote industry development within a regulated environment and enhance overall industry standards.

Li Shoushuang, managing partner of Dacheng Law Firm, told Shanghai Securities News that 2026 is expected to mark a new starting point for the upgrading of private fund regulations and supervision rules. 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 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 clearly increased content,” said a person in charge of Fresh Capital Investment. “Standardized disclosure helps upgrade the transparency of 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 also mandate the inclusion of requirements such as penetrating disclosure 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 will back up the disclosed content on the designated information disclosure backup platform of the CSRC. The backup platform does not serve as a disclosure channel; if information is only backed up but not disclosed through other channels, it will be considered as non-compliance with disclosure obligations.

According to a senior executive at 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, thus alleviating the “bad money drives out good” problem from a systemic perspective.

A senior official at Chongyang Investment told Shanghai Securities News that the Implementation Rules clarify a dual-track operation of “voluntary proactive disclosure + passive backup archiving.” Proactive disclosure ensures timely, convenient, and effective information sharing, while passive archiving guarantees the verifiability and traceability of disclosed information. This ensures that information is both “seen” and “findable,” pushing fund managers from “regulatory compliance” to “serving clients,” and fully safeguarding investors’ right to know.

Promoting Industry Transformation and Upgrading

The Disclosure Measures and Implementation Rules systematically cover the entire process of private fund operations for the first time, filling in the gaps in information disclosure during liquidation stages and safeguarding investors’ rights to full-process information. They also grant clearer self-regulatory authority to AMAC, significantly increasing the costs of illegal activities such as violations and misconduct.

A representative from Guotou Chuanghe Fund told Shanghai Securities News that this revision not only provides clearer rules for fund managers but also clarifies the implementation measures for AMAC’s self-regulation. 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 more 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 at Hei Wing 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.’”