Fund reporting runs on two separate tracks with different rulemakers and different deadlines. FCA rules require authorised funds to publish long reports within four months of the annual period and two months of the half-yearly one. Tax rules require offshore reporting funds to report to investors and to HMRC within six months. They are not the same document and not the same deadline.
The FCA side: long reports
Under COLL 4.5.3R, the authorised fund manager must prepare a long report for each annual accounting period and each half-yearly accounting period. The annual long report must contain accounts prepared in accordance with the requirements of the Statement of Recommended Practice.
The deadlines sit in COLL 4.5.14R(1): within four months after the end of each annual accounting period and two months after the end of each half-yearly accounting period, the AFM must make available and publish the long reports.
What "make available" means is worth being precise about, because it is often overstated. The reports must be supplied free of charge on request; be available in English for public inspection free of charge during ordinary office hours; for UCITS schemes, be available in specified EEA States; and be sent to the FCA. There is no requirement in the rule to send the long report to unitholders — it is made available and supplied on request.
The two reports inside it
Two separate reports accompany the accounts, and conflating them is a common error.
The depositary's report is required by COLL 4.5.11R. The auditor's report is COLL 4.5.12R — not 4.5.13, which does not exist. The auditor's report to the unitholders must state whether the accounts have been properly prepared in accordance with the SORP, the sourcebook rules and the instrument constituting the fund; whether they give a true and fair view; whether proper accounting records have not been kept; whether all information and explanations were given; and whether the AFM's report is consistent with the accounts.
The SORP: the 2025 edition
Anyone working from the 2014 SORP is working from a superseded document. The current version is the Statement of Recommended Practice — Financial Statements of Authorised Funds, October 2025, issued by the Investment Association.
It supersedes all previous SORPs for authorised funds, and its recommendations are applicable for accounting periods beginning on or after 1 January 2026. Earlier application is permitted provided the March 2024 amendments to FRS 102 are applied at the same time, with the corresponding disclosure made.
The FRC recognised the IA for the purpose of issuing the SORP and concluded that it was developed in accordance with the policy on developing SORPs and does not appear to contain fundamental points of principle that are unacceptable or to conflict with an accounting standard.
Note that COLL itself does not name an edition — it requires accounts prepared in accordance with "the SORP" — so the practical question for a December 2026 year end is whether the fund has adopted the new edition, and whether the FRS 102 amendments went with it.
Assessment of value
COLL 6.6.20R requires the AFM to conduct an assessment at least annually for each scheme it manages of whether the payments out of scheme property set out in the prospectus are justified in the context of the overall value delivered to unitholders.
The considerations are in COLL 6.6.21R — a separate rule, and a table rather than a list — assessed separately for each unit class:
- Quality of service;
- Performance, after deduction of all payments out of scheme property as set out in the prospectus;
- AFM costs — general;
- Economies of scale;
- Comparable market rates;
- Comparable services;
- Classes of units.
Publication runs through the annual long report. COLL 4.5.7R(8) requires it to include, at least, the AFM's conclusion for each unit class on whether the payments are justified, plus a summary of remedial action taken or planned. COLL 4.5.7R(9) offers an alternative: the information need not go in the annual long report if it is made available to unitholders annually in a composite report covering two or more funds, published in the same manner.
On deadlines, be careful. There is no free-standing four-month deadline for the assessment of value statement. Where it sits in the annual long report it picks up the four-month deadline in COLL 4.5.14R(1) — four months from the end of the annual accounting period, not from an accounting reference date. Where the composite route is used, the rule requires only that it be published annually in the same manner as the annual long report.
Alongside this sits COLL 6.6.25R: at least one quarter of the members of the AFM's governing body must be independent, and where the body has fewer than eight members, at least two must be. Appointments are capped at five years each and ten years cumulative.
The tax side: offshore reporting funds
This is a wholly separate regime under the Offshore Funds (Tax) Regulations 2009, and its deadlines are the ones investors care about.
Applying for reporting fund status. The application is made in writing to HMRC and must arrive before the later of the end of the first period of account for which the regime is to apply, or the expiry of three months beginning with the first day on which interests are made available to UK-resident investors.
Computing reportable income. The computation starts from total comprehensive income for the period under international accounting standards, or equivalent entries in the fund's accounts, then adjusts for capital and miscellaneous items, special classes of income and units in issue. Each item is adjusted once only, and a negative result gives reportable income of nil.
Reporting to participants. A report must be made available to each relevant participant for each reporting period, within six months beginning with the day immediately following the final day of the reporting period. Relevant participants are those UK-resident, or themselves reporting funds, during any part of the period. "Made available" covers post, electronic communication, a website accessible to participants and HMRC, or publication in a UK newspaper — and it must be in English.
Contents for a non-transparent fund include the amount actually distributed per unit, the amount per unit of any excess treated as additional distributions, distribution dates, the fund distribution date, whether reporting fund status is maintained, equalisation amounts where relevant, and per-unit amounts expressed to at least four decimal places.
The annual return to HMRC. For each period of account the fund must provide audited accounts, the computation of reportable income, a copy of the participant report for each reporting period, reported income, amounts actually distributed, units in issue at the end of each reporting period, reported income per unit, and a compliance declaration — within six months of the end of the period of account.
Excess reportable income
The market shorthand is "excess reportable income"; the legislation does not use the phrase. Under regulation 94, for a non-transparent reporting fund the Tax Acts apply as if the excess of reported income over amounts actually distributed were additional distributions to participants in proportion to their rights, treated as made on the fund distribution date — the date six months following the last day of the reporting period — or on such earlier date as the income is recognised in the participant's accounts. It is then charged to income tax as an offshore fund distribution.
That is why a UK investor in an accumulating offshore fund has taxable income without receiving cash, and why the fund's report is the only place the figure comes from.
Note on HMRC guidance: the standalone Offshore Funds Manual has been superseded. Offshore funds guidance now sits in the Investment Funds Manual.
What to keep separate
Three deadlines, three audiences. Four months and two months, to the FCA and the public, under COLL. Six months to participants and six months to HMRC, under the tax regulations. And the assessment of value, which rides on the annual long report rather than having a deadline of its own.
Our guide to asset and wealth management covers the surrounding audit and prudential work.
Acumon audits authorised and offshore funds and their managers through financial services audit, with CASS audit and tax compliance alongside. If your fund has a December year end, whether it has adopted the October 2025 SORP is the question to settle before the audit starts.