AIMA Regulatory Horizon Scan

The industry is entering a challenging period of regulatory change.  Regulators worldwide have been focused on adjusting their regimes, but some, such as the US Securities and Exchange Commission, have been particularly active in proposing changes to the requirements applicable to fund managers. Many of the proposed amendments are still pending, but we wanted to help members understand the potential overlaps in compliance periods to assist them in forward planning. To this end, AIMA has created the "AIMA Regulatory Horizon Scan".   

All dates for pending proposals are estimates and subject to change.

Current Weekly Horizon Scan

The horizon scan is refreshed weekly. A new version is posted each Monday (Tuesday following most U.S. and UK holiday weekends).

Download the current Horizon Scan

Frequently Asked Questions

How can I access more information about the requirements?

Most of the final rules and pending proposals in the lefthand column have a link under it in the PDF version of the AIMA Regulatory Horizon Scan. Clicking that link will take you to another AIMA website page where, for most of the items on the list, you can read a high-level summary of what is required or proposed to be required. You can also view the full timeline there, and members can access AIMA's work to date on the matter. Where relevant, this page will also contain links through which members can access a full summary of what is required, relevant multimedia content and/or implementation guidance.

For some of the items, this link takes members directly to a summary of what is required. In this instance, there will be no additional information available for non-members.

Does the weekly horizon scan include every proposal and every final regulatory requirement with an open compliance period?

No. This is a curated selection of items that AIMA staff have compiled based on the work we have performed on members behalf. Choices are made about which proposals AIMA does or does not respond to and similar types of choices have been made here. There will be proposals and final requirements that will affect members but which will not be included in the AIMA Regulatory Horizon Scan. Members are urged to use the weekly horizon scan in conjunction with other resources available to them when deciding whether they have addressed all applicable regulatory requirements.

How are the dates for pending proposals estimated?

For proposals that have not been published in final form, all of the dates are ESTIMATES. We have made these estimates in good faith based on the limited information available to us, and users should understand that all such dates are subject to frequent change. Where possible, the estimates are based on information from the regulators themselves, such as Regulatory Flexibility Agendas published by US regulatory agencies semi-annually and indicative lists showing matters to be prioritised during a given European Council Presidency term. However, even with these insights, the estimates have to be adjusted due to the passage of time and the regulator's overall workload. For each pending proposal, the webpage accessible via the link under the proposal's name includes a full explanation of the basis for that proposal's indicative dates.

The lists of dates are confusing. How should these be read?

All dates are in US format. In the "start" and "end" columns, this means "mm/dd". Across the top horizontal axis, the dates are shown as "mm/yy". To give the dates in the "start" and "end" columns appropriate context, you need to also refer to the year as well in the top horizontal axis.

The weekly horizon scan is currently set to cover dates through the end of 2024. When a compliance period ends in 2025 or 2026, those end points are not shown in the weekly horizon scan, but they are shown in the timeline in the linked webpage.

What do the colours of the bars signify?

The bars are different colours to indicate their relative priority and impact. These are judgments made by AIMA staff for the convenience of users, although we appreciate that users could have different views about proposal's priority or impact on their own business.

Bar Color

Priority

Impact

Bright orange

High

High

Bright pink

High

Medium

Red-orange

High

Low

Lavender/purple

Medium

High

Mid-dark blue

Medium

Medium

Sky blue

Medium

Low

Bright blue

Low

High

Lime green

Low

Medium

Bright yellow

Low

Low

While more distinct colour differences, or primary colours, would arguably be more effective, we have been constrained by the limits of the software we are using to generate the AIMA Regulatory Horizon Scan. If you cannot tell the colours apart but want to understand what priority/impact has been assigned to a specific item, click the link under the item name and go to the section of the webpage that is labelled "Timeline" where this information is presented and the colour of the bar identified.

Why do some of the items have two bars?

In some instances, the final rules or the proposal includes a split compliance obligation. Some matters are due at one compliance deadline, and other matters are due at a later date. In the alternative, some affected parties must comply by one date and others by another. These differences are reflected in the separate bars for clarity.

Why do the bars start where they do?

The start dates are set to the publication date on the relevant authority's website and not the Federal Register, Official Journal or similar. These extra days can be used for planning even if the text is not yet officially recognised.

How does the AIMA Regulatory Horizon Scan differ from the AIMA Regulatory Almanac?

The AIMA Regulatory Horizon Scan is a weekly snapshot of requirements that are either: (i) final and are therefore subject to implementation/compliance by the dates indicated; or (ii) pending finalization by the applicable regulator but close enough to completion to be able to provide a reasonable estimate of the specific date when final requirements may be published and when implementation/compliance will be required.  Each item is assigned a high, medium or low impact and a high, medium or low priority, with a different colored bar representing each combination of impact and priority.

The AIMA Regulatory Almanac is a more complete list of the final requirements and pending proposals on the radar of AIMA staff as this list includes matters that have not developed sufficiently for date estimates to be created for purposes of the AIMA Regulatory Horizon Scan. The dates listed are broader estimates than those in the AIMA Regulatory Horizon Scan and are less likely to change as the Regulatory Almanac is updated each month. Each almanac listing briefly describes the nature of the requirements and the key operational impacts/challenges. Each item is also assigned a designation as red, amber or green ranked in the level of severity of impact with red being the most severe, amber intermediately severe, and green the least severe.