Key Changes for International Fund Distribution in Saudi Arabia, Guernsey and Italy

Regulatory Updates March 2026

As global fund distribution continues to evolve, regulators are refining the frameworks governing exchange-traded funds, fund distribution channels, and regulatory fee structures. In order to maintain efficient and compliant market operations, it is essential for investment managers who operate across multiple jurisdictions to understand these developments.  

In this month’s blog, we report on recent developments concerning the marketing of investment funds in Saudi Arabia, Guernsey and Italy. 

Saudi Arabia  

In Saudi Arabia, the regulatory framework for fund distribution has been updated following the publication and implementation of two Federal Decree Laws governing the Capital Markets Authority (CMA) and the Regulation of Capital Markets, which came into effect in January 2026. 

The most notable change is the expansion of the categories of entities authorised to distribute fund units in Saudi Arabia. In addition to existing distribution channels, the CMA now permits Investment Fund Management Distribution Platforms and Electronic Money Institutions licensed by the Saudi Central Bank to distribute investment fund units according to Article 17 (f) of the Investment Fund Regulations. 

Guernsey – Private Placement rules and 2026 fees 

Guernsey has updated the legal framework governing foreign funds offered within the jurisdiction, including revisions affecting the use of the Designated Jurisdiction exemption. Guernsey has updated the laws governing foreign funds offered in Guernsey. These changes affect the “Designated Jurisdiction” exemption. 

The updated framework provides additional clarity on the application of the exemption.  

In addition, the Guernsey Financial Services Commission has increased certain fees for 2026, effective from 1 January 2026: 

• Form EX application fee: increased from GBP 1,470 to GBP 1,525 

• Annual fee for Exempt Non-Guernsey Schemes: increased from GBP 735 to GBP 765. 

The list of fees can be found here. 

Italy – 2026 Regulatory Fees 

The Italian Regulator Commissione Nazionale per le Società e la Borsa (Consob) has also increased the fees payable for the offering of foreign investment funds in Italy from January 2026.  

As of 2 January 2026, regulatory fees for foreign UCITS and AIFs have been harmonised to the same amount. The fee schedule for the 2026 financial year was established under a single resolution—No. 23799 of 17 December 2025—which also sets out the deadlines and procedures for the payment of fees. The resolution can be found here. 

The updated fees for European UCITS and AIFs are as follows: 

UCITS 

• EUR 2,100 per registered fund or sub-fund. 

Important to note is that where the offer has been closed, but Italian investors remain invested in the UCITS, the fee is still payable. 

AIFs 

• EUR 2,100 per registered fund or sub-fund. 

Outlook 

For investment managers distributing funds globally, maintaining visibility over these changes remains essential for ensuring compliant market entry, managing regulatory costs, and adapting distribution strategies as regulatory frameworks evolve. 

This is precisely where Zeidler’s Global Knowledge Hub provides value. By consolidating jurisdiction-specific rules, regulatory developments and practical legal and regulatory guidance into a single structured platform, GKH enables firms to quickly understand how changes in different markets affect their distribution strategies.  

With coverage spanning more than 80 jurisdictions and continuously updated by Zeidler’s legal and regulatory specialists, the platform supports informed decision-making across complex cross-border frameworks. 

Notably, Zeidler Group is continuously expanding the country and topic coverage of the Global Knowledge Hub. With the European exchange-traded funds (“ETF”) market experiencing continued growth, regulators and exchanges are increasingly focused on providing clarity around the structure and listing of ETFs. To support investment managers navigating this expanding segment, Zeidler has included new guidance now provides an overview of the rules governing ETFs, addressing common questions related to their structure, operation and key regulatory considerations. 

Our newly added content in Global Knowledge Hub (GKH) outlines the general process for listing securities on a stock exchange, with particular focus on ETF listings across key European markets, including: 

• Ireland – Euronext Dublin 

• Germany – Deutsche Börse 

• Switzerland – SIX Swiss Exchange 

These markets remain central hubs for ETF listings in Europe, and understanding the specific listing procedures and requirements in each jurisdiction is an important step for managers considering ETF launches or cross-border distribution strategies. 

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