New Focus in Fund Annual Report Disclosure! Details of penalties for 29 institutions revealed, some suspended from new issuance

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Topic: 2025 fund annual report season kicks off: top-tier public funds’ “trillion-dollar battle” escalates, Industrial and Commercial Fund (ICBC Credit Suisse) leads on net profit in the “profit leaderboard” reshuffle

Jiemian News reporter | Han Li

As 2025 fund annual reports are gradually released, information about regulatory penalties imposed on fund companies that year is coming to light step by step.

According to Jiemian News reporter incomplete statistics, throughout 2025, at least 29 public fund firms received administrative regulatory measures issued by regulators, such as warning letters and orders to rectify, among others. Some public fund firms also faced penalties including suspension of product registrations or business application approvals.

Jiemian News noted that, compared with past annual reports, the investigation or penalty information disclosed by various fund companies in their 2025 annual reports is more detailed. As for the reasons behind newly added specific items, multiple public-fund industry insiders told Jiemian News reporter that this is due to regulatory requirements.

Source: Fund annual reports, compiled by Jiemian News

Jiemian News reporter reviewed the CSRC’s “Guidelines on the Content and Format of Information Disclosure for Publicly Offered Securities Investment Funds, No. 2—Content and Format for Periodic Reports,” in which Article 33 shows that annual reports and interim reports must briefly disclose the following major events occurring during the reporting period, including cases where the fund manager, custodian, and relevant practitioners are investigated or penalized. Meanwhile, the Asset Management Association of China also published specific templates for fund disclosure compliance on its website.

Source: Asset Management Association of China

Under the specific types of measures, the template indicates that the specific type of measure must be filled out according to the major category. For example, administrative penalties include warnings, notification of criticism, fines, confiscation of illegal proceeds, and so on. Administrative regulatory measures include orders to rectify, regulatory talks, issuing warning letters, suspension of part or all business, etc.

Previously, when disclosing relevant penalties, how did each fund company handle it?

Jiemian News reporter noted that before 2022, because regulators had not made explicit requirements for fund companies’ disclosure of related matters, some fund companies would brush past it in a single line, while others would describe it simply.

“A lot of it wasn’t that clear in actual implementation—especially how to disclose specifically, and whether it needs to be disclosed down to individuals—none of that was clearly required.” A compliance insider at a public fund firm said.

The insider also said that from the perspective of fund companies, they also hope to avoid investors becoming aware of regulatory penalties, to prevent situations where large-scale redemptions of funds occur.

However, in August 2022, the Asset Management Association of China released “Securities Investment Fund Information Disclosure XBRL Template No. 3—Annual and Interim Reports (August 26, 2022),” and explicitly clarified the disclosure format. After that, the inspection and penalty information in fund annual reports became clear accordingly.

And in the latest 2026 version, the Asset Management Association’s template was upgraded again. Not only do firms need to clarify the major categories of investigation or penalty measures received, but the specific penalties are also further broken down in detail, and it is also necessary to list the basis for the penalties.

That said, in actual disclosures, there is still “room for practical maneuvering.” Taking Bosera Fund as an example, it shows that, due to compliance and internal controls, the Shenzhen CSRC ordered rectification and suspended part of the business, but it did not clearly state which specific part of the business was suspended or the duration of the suspension.

According to statistics compiled by Jiemian News, in 2025, 29 fund companies were investigated or penalized by regulatory authorities. Multiple leading fund companies were on the list. Regulatory measures cover both administrative regulatory measures and administrative penalties, with penalty forms including issuing warning letters, orders to rectify, suspension of business, and even fines.

Looking at the types of penalties, “compliance and internal controls” and “investment operations” became high-frequency problem areas. Even some companies, because the issues were severe, faced suspension of applications to register fixed-income public fund products for 3 months.

Both Haitong Fortune Fund and Chuangjin Hexin were penalized for their private asset management products. Haitong Fortune received an administrative regulatory measure of issuing a warning letter from the Shanghai CSRC due to issues such as non-compliant investment management in its private asset management business. Chuangjin Hexin, due to problems in areas including investment operations and sales management—such as partially incomplete internal control systems or ineffective implementation—was ordered to rectify and to suspend the filing of new private asset management product registrations for 3 months.

It is worth noting that some companies’ issues are intertwined across multiple dimensions. For example, China Merchants Fund has weaknesses in multiple areas, including corporate governance, compliance and internal controls, investment operations, and personnel management, and it also involves sales and financial management.

In addition, administrative penalty cases also cannot be ignored. Manulife Fund was warned and fined for violating foreign exchange registration management regulations. Founder Fubon Fund was required to pay back unpaid taxes and penalties because it failed to withhold and remit individual income tax as required, showing that regulation has not only been limited to the investment business level, but has also extended to the company’s basic compliance and tax management.

Some industry insiders say that the regulatory measures centrally disclosed in this round of annual reports reflect regulators’ stance toward strict governance of the fund industry. Whether it is leading institutions or smaller fund companies, they need to continuously strengthen compliance building, personnel management, risk control, and more. The industry is entering a new stage of “strong regulation and strict accountability.” Only by solidifying the foundation of internal controls can firms go steadily and far amid increasingly fierce market competition.

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责任编辑：石秀珍 SF183