As global regulators continue to refine frameworks governing cross-border fund distribution, investment managers face constant regulatory, operational, and cost-related changes. From changes in supervisory authorities to cross-border investment service exemptions, revised disclosure requirements, and updates to regulatory fees, staying informed is essential for maintaining compliant distribution strategies across multiple markets.
Recent developments that we focus on in this article illustrate how regulators are sharpening oversight while adjusting practical requirements for market participants.
In the United Arab Emirates, the regulator formerly known as the Securities and Commodities Authority (“SCA”) has officially changed its name to the Capital Markets Authority (“CMA”) on 1 January 2026. This change reflects a broader regulatory restructuring and has now been formally adopted across regulatory materials and guidance.
In addition, the CMA has published two new Federal Decree Laws governing:
The FLD33 clarifies that marketing of foreign funds falls within UAE regulation where UAE investors are targeted, regardless of where the marketing activity is conducted. It reinforces the requirement for regulatory approval to offer foreign funds onshore and strengthens the CMA’s supervisory and enforcement powers.
Following the effective date of the Berne Financial Services Agreement (the “BFSA”) on 1 January 2026, a mutual recognition framework, the United Kingdom and Switzerland have introduced a new framework allowing Swiss and UK investment firms to provide certain investment services to wholesale and sophisticated clients on a cross-border basis.
The agreement sets out the scope of investment services covered by the relevant exemptions and the conditions and requirements firms must meet to rely on it.
Eligible firms must be authorised to provide these services in their home country and be listed on the relevant BFSA register. The BFSA acknowledges that the UK and Switzerland maintain supervisory and regulatory regimes of comparably high standards. As a result, firms are not required to comply with regulatory requirements in the host country, as each country defers to the other’s regulatory and supervisory rules.
The UK Prudential Regulation Authority (“PRA”) and the UK Financial Conduct Authority (“FCA”) have jointly published guidelines to assist firms that are considering providing services under the BFSA. Additionally, the Swiss Regulator (“FINMA”) has also published guidance concerning the BFSA on its website.
In September 2025, the Icelandic Regulator published updated guidance concerning the language requirements of key information documents. In specific cases, and subject to certain considerations, it is now permitted to provide investors with a PRIIPs Key Information Document in English in limited cases. As a general rule, if a PRIIP is promoted in Iceland with marketing documents in Icelandic, the Key Information Document must at least be in Icelandic language.
In Circular No. 19/2025, the Icelandic Financial Supervisory Authority acknowledged that Key Information Documents for packaged investment products may be in English language under certain conditions. These conditions are:
Further, the Circular states that if an investment product is marketed in Iceland or in Icelandic and the investor is provided with a Key Information Document in English, a Key Information Document in Icelandic must also be provided. For example, in cases of reverse solicitation, where an investors requests to invest in a product that is not marketed in Iceland or in Icelandic, an English KID is sufficient, when the other conditions above are met.
The Jersey Regulator has published its fee schedule for 2026, effective from 1 January 2026. The annual fee for an application for public offering in Jersey will increase to GBP 703 from GBP 686.
The Isle of Man Regulator has also released its 2026 fee increases, effective from 1 April 2026.
Recognised schemes from designated territories
Individually recognised schemes
Application fees:
Annual fees:
The Swedish Regulator has announced a significant fee increase for Article 42 AIFMD registrations, effective from 1 January 2026. The application fee was increased to SEK 25,500 from SEK 18,000.
The recent developments demonstrate how regulators are refining both the mechanics of market access and the cost and disclosure frameworks that underpin cross-border fund distribution. For investment managers operating across multiple jurisdictions, even incremental changes, such as revised fee structures, language flexibility, or new cross-border service exemptions, can have meaningful operational and commercial implications.
Staying informed allows firms to adapt distribution strategies proactively rather than reactively.
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