Measured The New Way, Your Firm May Not Be The Size You Think It Is.
On 14 July 2026 the FCA proposed moving the small-firm ceiling from £100m to £750m, and changing what gets measured: net asset value rather than leveraged assets under management, averaged across a calendar quarter rather than taken on a single date. Either change on its own can move a firm across the line. This is the calculation worked properly, what crossing costs, and twelve questions you can run against your own numbers in an afternoon.
Free PDF guide
The £750m Question
A ten-page briefing on the FCA's proposed UK AIFM regime: which tier your firm falls into, how the calculation actually works now that it is net asset value on a quarterly mean, and what it costs to cross the line.
Artizan Governance
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- $850bn+ in client assets under frameworks built
- $700bn MiFID II build across EMEA
- Two decades at the regulatory coalface
- Seven regulators, one coherent framework
Inside The £750m Question
A manager reading its own size as £825m on gross exposure is £645m measured net, and sits in the small regime with about £105m of headroom it did not know it had. The arithmetic is on page three.
The vehicles finance teams tend to leave out, the co-invest structures, the continuation vehicles, the parallel funds, are frequently the ones that decide which side of the line you land on.
Crossing upward is no longer a variation of permission. It is a SUP 15 notification and two clocks: six months for the new obligations, twelve where a depositary becomes newly required. Which clock applies is the whole cost of the boundary.
Your classification will never appear on the Financial Services Register. An LP or an operational due diligence team cannot look your tier up, which makes it a question you answer with your own evidence or not at all.
Tools you keep. Not tips you forget.
Where the line actually fell, and why
The Call for Input proposed £100m. Respondents pointed out that this was a cut on the current €500m test for closed-ended, unleveraged funds, and would pull firms into a heavier regime at the moment the reforms were meant to lighten one. The FCA took €500m as its baseline, uprated it for inflation to roughly £640m, and set the line at £750m. Small below £750m, medium to £5bn, large above.
The calculation, in four steps
Identify every AIF you manage plus any residual non-AIF, non-UCITS collective investment scheme you operate. Value it under the valuation rules. Take the mean net asset value for each AIF across the most recent calendar quarter rather than a spot figure. Then aggregate and compare. Worked end to end on real numbers, including the gross-versus-net example that lands in two different tiers.
What sits on each side of the line
A side by side of small, medium and large: depositary per AIF against CASS 6, which rule set attaches, the six-month and twelve-month compliance clocks, and the provision most firms miss, which is what happens to both clocks when a volatile book crosses twice in the same calendar year.
The gateway, if you are a small registered AIFM
Roughly 23% of the 661 sub-threshold UK AIFMs were small registered firms in 2025. The Treasury proposes removing that regime for all but Registered Venture Capital and Social Enterprise Funds, with no grandfathering. Threshold Conditions, the Principles, capital, Senior Management Functions and full reporting all arrive at once. The FCA puts the cost to that population at £65.6m over a ten-year appraisal period.
Twelve questions, scored
Four on where the firm lands, four on what follows from it, four on what the firm would then have to do. Score each 2 if you can answer it now with a number, 1 if you could reach an answer with work, 0 if you cannot answer it yet. At 20 or above you know enough to respond to the consultation on your own facts. Below 12 you are still making structuring decisions on a basis that is being withdrawn.
One email. The whole kit.
The £750m Question, ten pages, written for practitioners rather than for a mailing list
The four-step classification test, with the worked example where gross exposure and net asset value land the same firm in different tiers
The side-by-side of small, medium and large: depositary, rule set, and both compliance clocks
The twelve questions, scored 0, 1 or 2, so you finish with a number rather than an impression
Every figure referenced to the paragraph of CP26/28 it came from, so a sceptical general counsel can check rather than trust
A free 30-minute Compliance Cover Call, which ends with the two or three things the FCA would challenge first in your own answers
Who’s behind this
Asad Bukhory
Founder, Artizan Governance
Asad has spent two decades at the regulatory coalface, holding sole SMF16 and SMF17 roles personally and building the controls behind some of the largest balance sheets in this market. More than $850bn of client assets sit under frameworks he built, including a $700bn MiFID II build across EMEA, harmonised across seven regulators. He founded Artizan to bring that standard to the firms that need it most and can rarely reach it: the ones where the entire control function is one person.
Measured The New Way, Your Firm May Not Be The Size You Think It Is.
On 14 July 2026 the FCA proposed moving the small-firm ceiling from £100m to £750m, and changing what gets measured: net asset value rather than leveraged assets under management, averaged across a calendar quarter rather than taken on a single date. Either change on its own can move a firm across the line. This is the calculation worked properly, what crossing costs, and twelve questions you can run against your own numbers in an afternoon.
Free. No card. One click to unsubscribe.
Questions, answered
Is this actually free, and is there a catch?
It is free and there is no catch. No card, no trial. You give me a name and a work email, I send you the access link. If the emails afterwards are not useful, one click and they stop.
I am not an AIFM. Is it still worth my time?
Probably, if you manage alternatives in any form. Most of the programme is governance, valuation, delegation and reporting practice the FCA applies well beyond the AIFMD perimeter. If you run long-only UCITS and nothing else it will be less useful, and I would rather tell you that now than waste your evening.
How long does it take, and do I have to do it in one sitting?
Roughly four hours across sixteen modules, and no. It is built to be picked up and put down, which is the only realistic way anyone in this job gets through anything.
Artizan Governance: governance, risk and compliance for FCA-authorised investment firms. From documented to evidenced.