On 27 August 2026 AIMA provided feedback on paragraphs 9.4 to 9.11 of the FCA’s Consultation Paper 26/26 regarding the transition to mandatory online submissions for fund reporting through the Gateway system. AIMA's response highlights practical concerns with the current portal design and suggests alternatives to improve the process.

We noted challenges with respect to the functionality of the online portal such as restricted login access, poor review and printing functions, mandatory fields that limit meaningful answers, and sequential page gates that hinder holistic form review and coordination among stakeholders. AIMA suggested the FCA consider keeping forms publicly accessible, enabling delegation and allowing external advisors to participate without login credentials.  We also pointed out that portal outages also pose risks despite a 24-hour fallback provision.  

AIMA's response also pointed out that the data collected in application and notification processes overlap with numerous data points in the annual/quarterly FRAME reporting templates and recommended assigning single datapoint designations for overlapping information to avoid duplication and ensure consistency.  We suggested that the information submitted during authorisation/notification should not be re-entered in annual/quarterly reports. Since updates must be provided before material changes, this data should be more current than lagged periodic reports. If overlapping questions remain, pre-populating responses using authorisation data was suggested to prevent conflicting submissions. 

Please contact Jennifer Wood ([email protected]) with any questions on this response.