FCA Weighs Mandatory Quarterly Disclosure Rules for Private Credit Firms as Regulator Coordinates with FSB and IOSCO on Systemic Risk Framework
The Financial Conduct Authority (FCA) is considering introducing a compulsory quarterly disclosure regime for private credit firms operating in the UK — a market in which investors lend directly to companies outside the traditional banking system, typically via funds — according to a Bloomberg report cited by Private Equity Wire. The FCA is coordinating its review with the Financial Stability Board (FSB) and the International Organisation of Securities Commissions (IOSCO), signalling that any UK framework is being designed with international alignment in mind. The proposal follows a volatile period for private markets. The so-called 'SaaSpocalypse' — a sharp repricing of software-sector loans that drove investor withdrawals from private credit funds — combined with the collapse of UK property lender MFS and US subprime auto lender Tricolor in 2025, has sharpened regulatory focus on hidden risks within the asset class. Apollo Global Management has separately announced plans to begin daily pricing of its private credit portfolio by end of September, illustrating how market leaders are moving ahead of formal regulation on transparency. Separately, the European Central Bank (ECB) has published stress-test modelling showing that European insurers, which hold approximately €211 billion in private credit exposure (around 2.3% of total assets), would face larger losses than banks in a severe market shock — because of their less senior, more equity-like positions.
Why this matters
Mandatory quarterly disclosure for private credit funds would represent the most significant structural regulatory intervention in that market since its rapid post-2015 growth. For law firms, the proposal creates immediate demand for regulatory compliance work: fund managers would need to redesign reporting infrastructure, negotiate amended fund documentation with LPs (limited partners — investors in the fund), and engage with the FCA consultation process. The ECB stress-test finding on insurers adds a cross-border dimension, since UK fund managers often distribute to European institutional investors — meaning EU regulatory developments can feed back into UK product structuring decisions. The 'why now' trigger is clearly the combination of credit quality concerns, high-profile lender failures, and the SaaSpocalypse withdrawal episode: regulators are responding to demonstrated liquidity and valuation risk.
On the Ground
On a regulatory response engagement of this type, a trainee would assist in drafting regulatory notification letters to the FCA, updating compliance gap analysis memos comparing current fund reporting practices against the proposed quarterly disclosure requirements, and maintaining a remediation tracker as the firm maps steps needed to meet any new standards.
Interview prep
Question you might get
“How would mandatory quarterly disclosure requirements for private credit funds interact with the confidentiality obligations typically found in limited partnership agreements, and how would you advise a fund manager navigating that tension?”
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