CSRC Issues Measures for Supervision and Administration of Information Disclosure by Private Investment Funds

On February 27, 2026, the China Securities Regulatory Commission (CSRC) issued the Measures for Supervision and Administration of Information Disclosure by Private Investment Funds (CSRC Order No. 233) (the “Measures”), to take effect on September 1, 2026.

Comprising seven chapters and forty-four articles, the Measures apply to information disclosure to investors by private fund managers and custodians, as well as disclosure by sales institutions acting as agents. Disclosure must be true, accurate, complete, timely, use non-public channels, and be consistent across all channels. When managers entrust sales institutions with disclosures, this does not relieve the manager of their obligations; sales institutions may not alter disclosed information.

The Measures establish look-through (penetrating) disclosure rules: when investing in other private funds, asset management products (excluding public funds), or via SPVs, invested entities must cooperate. The Measures prohibit false records, performance forecasting, guarantees of principal or yield, public or disguised public offerings, etc.

On regular reports:

·Private securities funds must disclose net asset value, with open-ended funds reporting at least as often as open period frequency, closed-end funds at least quarterly; quarterly reports within one month from quarter-end, annual reports within four months from year-end; annual financial reports in specified cases must be audited by an accountancy firm meeting Securities Law requirements.

·Private equity funds’ semi-annual reports are due within two months of semi-annual close; annual reports within six months of year-end, with annual financial reports requiring audit.

Material events must be disclosed via ad hoc reports within five working days. Requirements are also set for liquidation announcements and reporting, information disclosure systems and management of non-public information, retention of materials for twenty years, and regulatory and penalty provisions.