In April 2025, HM Treasury launched a consultation, closing on 9th June 2025, on Regulations for Alternative Investment Fund Managers that sets out the Government’s proposed approach for a streamlined framework for the regulation of AIFMs and the depositaries they use.
What are the key points?
Within the HMT consultation document is a policy proposal for the Small Registered AIF regime. This regime applies to three categories of sub-threshold AIFMs and exempts them from the requirement to seek FCA authorisation when managing certain AIFs. The three categories of firm are:
- Managers of Social Entrepreneurship Funds (SEF) and Registered Venture Capital Funds (RVECA);
- Managers of Unauthorised Property Collective Investment Schemes, meaning AIFMs managing assets of unauthorised funds mostly holding land, and;
- Managers of ‘Internally Managed Companies’, meaning investment companies which are not collective investment schemes and which do not appoint an external AIFM.
The Government proposes to remove the legislative thresholds for the Small Registered regime, so that all firms currently within the regime would in future fall within the regulatory perimeter. This means that they would be required to seek FCA authorisation and comply with a proportionate set of rules based on their size.
How can we help you?
Thistle Initiatives has supported Alternative Investment Fund Managers for over 10 years as a trusted compliance and regulatory adviser. In addition to assisting these firms as-and-when, our team of specialists can serve as your right hand in complying with FCA regulations. We understand the importance of staying up-to-date and compliant and are dedicated to providing the guidance and support needed to do so.
If you are looking for help with your AIFM arrangements, or have more general regulatory questions, we can help in any of the following ways;
- Advising firms considering applying for FCA authorisation as AIFMs
- Supporting FCA authorisation applications
- Advising registered AIFMs on the implications for them of becoming authorised
For more information and details on how we can support with your AIFM arrangements, please contact our Investments Partner, Alex Paschalis: alex.paschalis@thistleinitiatives.co.uk
Meet the expert
Alex Paschalis, Partner, Investments 
Alex joined Thistle Initiatives in 2015 after two decades of working with complex financial products. Alex's diverse experience in financial services includes roles across front office trading and dealing, management, and consultancy, offering valuable insights into FCA compliance and regulations.
As a former proprietary trader, Alex handled various financial instruments, transitioning from open outcry to various trading platforms. Additionally, Alex served as a Compliance Business Analyst, supporting multi-asset trading teams.
Alex's expertise extends to FCA compliance auditing, oversight, and advisory services on enforcement actions and MIFID audits. Alex holds a CISI diploma in investment compliance and a CFA certificate in investment management.