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

Author: Liang Yinyan

Just two weeks after the issuance of the first administrative regulations on private fund information disclosure, the supporting detailed operation manual—the “Implementation Rules for Private Equity Fund Information Disclosure (Draft for Comments)” (hereinafter referred to as “Implementation Rules”) and the “Key Content Template for Private Equity Fund Information Disclosure (Draft for Comments)” (hereinafter referred to as “Key Content Template”)—have recently solicited public opinions. This marks that the regulation of information disclosure for the private market worth 22.4 trillion yuan is accelerating from制度 design to practical implementation.

Industry insiders believe that the Implementation Rules and Key Content Template further完善 the self-regulatory framework for private equity funds. Once officially released, they will form an information disclosure system of “departmental regulations + normative documents + self-regulatory rules” for private funds. This “Rules + Templates” combination will turn principled provisions 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 “Supervision and Management Measures for Private Fund Information Disclosure” (hereinafter referred to as “Disclosure Measures”) on February 27.

Guotai Haitong Securities officials told Shanghai Securities Journal 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, enhance the规范性 and transparency of private fund disclosures, and lay a制度 foundation for high-quality industry development.

“The Implementation Rules translate the requirements of the Disclosure Measures into clearer enforcement standards and operational checklists, focusing on core aspects such as periodic reports, interim reports, and liquidation reports. They specify quantitative requirements for透视 disclosure, cross-border investments, and重大 related-party transactions, ensuring the effective implementation of the Disclosure Measures at the industry level,” a senior executive from Fresh Capital Investment told Shanghai Securities Journal.

The main负责人 of the CSRC previously stated that for private funds,完善 the "1+N+X"制度体系, improve制度 rules for access, fundraising, custody, and disclosure, and严厉打击 illegal activities such as违规募集,侵占挪用,自融自用, and利益输送. This will promote行业规范发展 and提升行业水平.

Li Shoushuang, managing partner of Dacheng Law Firm, told Shanghai Securities Journal that 2026 is expected to become a new starting point for the升级 of private fund industry regulations and监管 rules. As the "1+N+X"制度体系 continues to完善, the industry will迎来 a more立体,规范, and完善 legal environment.

Ensuring Information Disclosure is “Seen and Can Be Checked”

According to the Implementation Rules and Key Content Template, the specific内容 disclosed by managers to investors should meet or exceed the requirements of the Key Content Template. The format can be自主设计 to reflect the特点 of private funds.

“Changes in the disclosure template are significant, with明显增加 of new内容,” a senior executive from Fresh Capital Investment told reporters. “Standardized disclosure helps upgrade transparency in private fund operations.” Managers are allowed to自主设定格式 based on product特点, ensuring core信息的标准化 and readability while retaining flexibility in fund strategies. The templates embed mandatory requirements for透视 disclosure and风险揭示,促使管理人提升 internal control水平 and compliance意识,推动私募行业向“主动透明”转变.

Meanwhile, private fund managers will back up the disclosed内容 on the CSRC-designated disclosure backup platform. The backup platform is not a disclosure渠道; if information is only backed up but not disclosed through other渠道, it will be regarded as未履行 disclosure obligations.

In the view of a负责人 from Shenzhen Capital Group,统一 and清晰的 disclosure standards will促使市场形成更有效的筛选机制, resource集中于规范运作、信息透明的机构,从制度层面缓解“劣币驱逐良币”问题.

A负责人 from Chongyang Investment told Shanghai Securities Journal that the Implementation Rules明确“主动披露渠道+被动归档平台”双轨运行, ensuring主动披露 for主动信息披露, and passive archiving for可验证 and可追溯 information. This ensures that信息披露既要“被人看到”, also要“有处可查”, pushing fund managers from “应付监管” to “服务客户”, fully保障投资者的知情权.

Promoting Industry Transformation and Upgrading

The Disclosure Measures and Implementation Rules systematically cover the entire process of private fund operations for the first time,补齐 the information disclosure短板 during liquidation,保障 investors’ full-process知情权;同时,赋予了AMAC更明确的自律管理权限, significantly increasing the违法违规成本 for private fund managers.

A representative from Guotou Chuanghe Fund told Shanghai Securities Journal that this revision not only provides clearer rules for fund managers but also明确 the implementation measures for self-regulation by AMAC. It benefits保护投资者的合法权益 and提升 private fund management机构的专业化运营能力, helping private funds operate规范透明 and赢得 investor trust.

“Implementation of the Disclosure Measures and Implementation Rules will推动 private fund industry向标准化、透明化、规范化转型,” said a senior executive from Hei Wing Investment. “Refined disclosure requirements and统一模板 will有效解决信息不对称问题, helping investors全面了解基金运作情况、风险水平和业绩;同时,倒逼管理人完善内部控制体系,提升信息披露质量,规范投资运作行为, those with不规范披露 and薄弱风控 will gradually be淘汰,助力实现“良币驱逐劣币”.”