Under the UK AIFM regime, alternative investment fund managers (AIFMs) are categorised into three regulatory classifications: Full-Scope, Small Authorised and Small Registered.[1] The categories reflect whether the manager’s assets under management (AUM) fall above or below the Small AIFM thresholds, and, for sub-threshold managers, whether they operate on an authorised or registered basis.[2] Sub-threshold AIFMs can also opt into Full-Scope authorisation.
Small AIFM thresholds:
A manager qualifies as a small AIFM where its total AUM does not exceed:
• €500 million, where all AIFs are unleveraged and investors have no redemption rights for at least five years; or
• €100 million in all other cases (including any assets acquired through leverage).
As at Q1 2026, there are 1,272 UK AIFMs based on the total number of authorised and registered AIFMs regulated by the FCA. Full-Scope AIFMs make up the majority (681 firms, or 53.5%), followed by 458 Small Authorised AIFMs (36%) and 133 Small Registered AIFMs (10.5%).
Firms with aggregate AUM above the small AIFM thresholds (i.e., >€100m incl. leverage, or >€500m unleveraged with a 5-year lock-in) or sub-threshold firms that opt up to Full-Scope authorisation. These firms are subject to the full UK AIFM regime, including capital requirements, risk and liquidity management, valuation, depositary appointment, and regulatory reporting.
Sub-threshold AIFM:
2.
Small Registered UK AIFM
Firms with aggregate AUM below the small AIFM thresholds that are subject to registration rather than authorisation, with limited ongoing obligations focused on registration and reporting.
3.
Small Authorised UK AIFM
Firms with aggregate AUM below the small AIFM thresholds that require, or elect to obtain, authorisation under Part 4A of FSMA. These firms are subject to authorisation and the applicable requirements of the UK AIFM regime.
1.
Regulation of Alternative Investment Funds
Regulated activity and FCA Permissions.
Managing an AIF is a regulated activity that covers the portfolio and risk management of alternative investment funds (AIFs). In practice, this activity is represented as two FCA permission variants based on the fund's authorisation status: Managing an Authorised AIF and Managing an Unauthorised AIF.[3]
These permissions apply only to authorised AIFMs (Full-Scope and Small Authorised), because Small Registered AIFMs operate outside the Part 4A permission regime and are instead supervised under a separate registration regime. Of the 1,272 UK AIFMs in total, 1,139 are authorised. Among the authorised firms, 27 hold only the Managing an Authorised AIF permission (2.4%), 1,040 hold only the Managing an Unauthorised AIF permission (91.3%), and 72 hold both (6.3%).
Frequency of Authorised Firms by ‘Managing an AIF’ Permission Type
Managing an AIF is a regulated activity specified in article 51ZC of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (RAO 2001),[4] based on the following points:
1.
Core Functions
A person that performs at least one of the following activities for an alternative investment fund is classified as managing an AIF:
• Risk Management
• Portfolio Management
2.
Extended Functions
The following activities are included within the Managing an AIF activity if the person manages an AIF and the activities are carried out for that AIF or in connection with the management of that AIF.
• 1) Administration: (i) legal and fund management accounting services; (ii) customer inquiries; (iii) valuation and pricing, including tax returns; (iv) regulatory compliance monitoring; (v) maintenance of unit-/shareholder register; (vi) distribution of income; (vii) unit/shares issues and redemptions; (viii) contract settlements, including certificate dispatch; (ix) record keeping.
• 2) Marketing: The marketing and promotion of the alternative investment fund.
• 3) Activities related to the assets of AIFs: Namely services necessary to meet the fiduciary duties of the AIFM, facilities management, real estate administration activities, advice to undertakings on capital structure, industrial strategy and related matters, advice and services relating to mergers and the purchase of undertakings and other services connected to the management of the AIF and the companies and other assets in which it has invested.
3.
Delegation
A firm is not treated as managing an AIF if the functions it performs for the AIF have been delegated to it by another person (e.g. risk or portfolio management), provided that the delegating AIFM has not delegated those functions to such an extent that it becomes a ‘letter-box’ entity.
1.2 Definition of Alternative Investment Funds
Under the UK AIFMD framework, an alternative investment fund (AIF) is a fund that meets all of the following conditions:
1: A collective investment undertaking
2: Has a defined investment policy
3: Raises and invests capital in accordance with the policy to benefit the investors
4: Not a UK UCITS
1.3 FCA Permission by Type of Alternative Investment Fund
The Managing an Authorised AIF permission enables a firm to manage alternative investment funds (AIFs) that are authorised by the FCA, which include Non-UCITS Retail Schemes (NURS), Long-Term Asset Funds (LTAFs) and Qualified Investor Schemes (QIS). [5,6] Unlike unauthorised funds that are typically marketed only to professional, institutional, or otherwise qualified investors, authorised funds may be marketed to retail investors depending on the fund type and the scope of FCA authorisation. [7,8]
Non-UCITS Retail Schemes (NURS)
Non-UCITS Retail Schemes (NURS) are FCA-authorised collective investment schemes that are alternative investment funds but are neither UCITS schemes nor Qualified Investor Schemes. They have fewer restrictions on their investment powers than UK UCITS schemes and can be marketed to retail investors in the UK.
The NURS regime allows investment in structures such as property authorised investment funds (PAIFs) that are designed to hold immovables such as commercial property within the authorised-fund framework. Within the limits set by FCA rules on eligible assets, concentration and borrowing, NURS can hold a range of assets and may invest in less liquid asset classes in line with the fund’s investment objective.
A NURS is treated as an authorised AIF under the UK AIFM regime. A firm that manages a NURS is therefore managing an authorised AIF and is required to hold the FCA Part 4A permission “Managing an Authorised AIF”.
Long-Term Asset Funds (LTAF)
Long-Term Asset Funds (LTAFs) are FCA-authorised open-ended collective investment schemes within the UK authorised-fund regime, categorised as alternative investment funds and established for investment in long-term illiquid assets. HMRC and FCA materials describe LTAFs as authorised investment funds whose units are available primarily to professional investors, with access for certain other categories of investor in line with FCA distribution rules.
Under FCA rules, the investment strategy of an LTAF is to invest mainly in long-term illiquid assets or in other funds that invest in such assets. FCA guidance expects LTAFs to invest more than 50% of the value of the scheme property in unlisted securities and other long-term assets, such as interests in immovables or other collective investment schemes investing in those assets.
The FCA rules introduce a mandatory minimum notice period of at least 90 days for redemptions and prohibit LTAFs from offering redemptions more frequently than monthly, with longer notice periods or less frequent dealing permitted where consistent with the fund’s strategy and liquidity profile.
For UK regulatory and tax purposes, an LTAF is treated as an authorised AIF. A firm that manages an LTAF is required to be a full-scope UK AIFM (or equivalent authorised AIFM) holding the Part 4A permission “Managing an Authorised AIF” and is subject to the UK AIFM regime in addition to the specific FCA rules that apply to LTAFs.
Qualified Investor Schemes (QIS)
Qualified Investor Schemes (QIS) are FCA-authorised collective investment schemes that are alternative investment funds open only to “qualified investors”. They have wider investment and borrowing powers than UK UCITS funds or NURS.
Qualified investors include professional investors such as institutional investors (for example pension funds and charities) and certain categories of retail investor that meet HMRC and FCA criteria for qualified or sophisticated investors. Units in a QIS may be promoted only to professional clients and those categories of retail client that meet the FCA’s eligibility criteria for investment in non-mainstream pooled investments.
QIS have the widest authorised-fund investment powers in the UK regime and can invest in a wide range of assets with relatively few category-based restrictions, subject principally to requirements on spread of risk and the fund’s stated investment objectives. QIS may invest in assets such as infrastructure, real estate, private equity, private debt and other financial instruments within this framework.
Both the manager and the fund are subject to requirements under the UK AIFM regime and FCA rules, including the Collective Investment Schemes sourcebook (COLL), covering conduct, depositary arrangements, risk management, governance and regulatory reporting, among other requirements. [9,10]
The Managing an Unauthorised AIF permission enables an AIFM to manage alternative investment funds that are not authorised by the FCA, which include structures such as private limited partnership funds, unauthorised unit trusts, Reserved Investor Funds (RIFs), closed-ended investment companies that qualify as AIFs, and non-UK AIFs managed or marketed from the UK. These funds are typically marketed only to professional, institutional, or otherwise qualified investors under exemptions from retail marketing restrictions. [11]
Limited Partnership AIFs (LP / PFLP)
Limited partnership AIFs are typically closed-ended private funds established as English or Scottish limited partnerships under the Limited Partnerships Act 1907 and, where they meet the “private fund conditions” (constituted by written agreement and qualifying as a collective investment scheme), may be designated as private fund limited partnerships (PFLPs) under the Legislative Reform (Private Fund Limited Partnerships) Order 2017.
These vehicles are used primarily for private equity, venture capital and other illiquid alternative strategies in which investors commit capital to be drawn down and invested over a long-term fund life, with investors holding partnership interests that are generally treated as interests in an unregulated collective investment scheme and a non-mass market/non-mainstream pooled investment, so that FCA rules on the promotion of UCIS and non-mass market investments effectively restrict marketing to professional clients and to certain categories of certified high-net-worth or sophisticated investors using the relevant financial promotion exemptions.
Unauthorised Unit Trusts (UUTs)
Unauthorised unit trusts (UUTs) are unit trust schemes that are not authorised or recognised under the FCA’s authorised-fund regime and instead fall within HMRC’s unauthorised unit trust regime, under which they are categorised for tax purposes as exempt unauthorised unit trusts (EUUTs), non-exempt unauthorised unit trusts (NEUUTs) or, in specified transitional cases, mixed unauthorised unit trusts (MUUTs).
EUUT status is available where the trustees are UK-resident, all unitholders are “eligible investors” (including certain pension schemes, authorised funds and charities) and HMRC approval is obtained, and UUTs (including EUUTs and pension fund pooling schemes) are commonly used for institutional and pension pooling mandates such as UK real estate portfolios, with investment, borrowing and dealing terms set by the trust deed rather than COLL and units typically constituting interests in an unregulated collective investment scheme and non-mass-market investment, so that promotion is generally restricted to institutional and other professional investors and, where permitted, qualifying high-net-worth or sophisticated investors under the UCIS and non-mass-market-investment financial promotion regimes.
Reserved Investor Fund (RIF)
The Reserved Investor Fund (RIF) is a UK-based unauthorised contractual co-ownership scheme established under a statutory regime that includes the Co-ownership Contractual Schemes (Tax) Regulations 2025 and the Unauthorised Co-ownership Alternative Investment Funds (Reserved Investor Fund) Regulations 2025, which together implement the new RIF vehicle as an unauthorised co-ownership alternative investment fund with modified investor rights akin to those in authorised contractual schemes.
HM Treasury and HMRC describe the RIF as a new fund structure designed to complement and enhance the UK’s existing funds regime by providing a UK-based unauthorised contractual scheme with lower costs and greater flexibility than authorised contractual schemes, open only to professional and institutional (including “large”) investors and expected to be particularly attractive for investment in UK commercial real estate and other illiquid assets, with detailed investment, leverage and liquidity terms set in the scheme documentation rather than by COLL.
Other Unauthorised AIF Structures
Other AIF structures commonly seen in practice include corporate AIFs (such as investment trusts and REITs) and non-UK funds that meet the Article 4(1)(a) AIFMD definition but are not UK-authorised schemes. Joint-venture and co-investment vehicles can also form part of the unauthorised AIF population where they are structured as collective investment undertakings under AIFMD and ESMA’s key concepts guidance, while joint ventures established as operational businesses with a general commercial or industrial purpose are usually regarded as outside the AIF perimeter.
The manager is subject to requirements under the UK AIFM regime and FCA rules, including FUND, SYSC, COBS and SUP, covering conduct, depositary arrangements (where required), risk management, governance and regulatory reporting, among other requirements, while the fund itself generally sits outside the FCA’s authorised-fund product rules in COLL.
2.
Regulatory Classification of UK AIFMs
Full-Scope, Small Authorised and Small Registered
UK AIFMs are classified as full-scope, small authorised or small registered UK AIFMs according to whether they meet the small AIFM definition in regulation 9 of the Alternative Investment Fund Managers Regulations 2013 (by reference to assets under management (AUM)) and whether they are authorised under Part 4A FSMA, registered under regulation 10, or have opted to be treated as full-scope UK AIFMs.[2]
2.1 Full-Scope UK AIFM thresholds and definition
Full-Scope UK AIFMs
Under UK legislation, a full-scope UK AIFM is an AIFM that holds a Part 4A permission to manage an AIF and is not a small authorised UK AIFM. In practice, this category comprises two types of firms:
• Firms whose aggregate AUM exceed the small AIFM thresholds; and
• Firms that remain below those thresholds but hold AIFM authorisation and have opted into the full-scope regime.
Full-scope UK AIFMs are subject to the full UK AIFM regime, including own funds and capital requirements, organisational and governance requirements, risk and liquidity management, valuation, depositary appointment, delegation conditions, transparency obligations to investors and AIFMD-derived regulatory reporting to the FCA.
2.2 Small Registered UK AIFM thresholds and definition
Small Registered UK AIFMs
A small registered UK AIFM is an AIFM that:
• is a small AIFM under regulation 9 (its aggregate AUM remains within the small-AIFM thresholds); and
• is subject to registration under regulation 10 of the AIFM Regulations rather than authorisation as an AIFM under Part 4A FSMA.
Small registered UK AIFMs are therefore sub-threshold managers whose obligations are centred on registration under the small AIFM regime, with limited conduct requirements and proportionate reporting to the FCA, and who are not subject to the full set of FUND 3 requirements that apply to full-scope UK AIFMs.
2.3 Small Authorised UK AIFM thresholds and definition
Small Authorised UK AIFMs
A small authorised UK AIFM is an AIFM that:
• qualifies as a small AIFM (its aggregate AUM remains within the small-AIFM thresholds); and
• holds a Part 4A permission to manage an AIF rather than being registered under the small AIFM registration regime.
Small authorised UK AIFMs therefore sit within the sub-threshold regime but are authorised firms and are subject to a proportionate application of the UK AIFM requirements calibrated to their scale and activities, alongside any other rules that apply to the permissions they hold. A small authorised UK AIFM that no longer meets the small-AIFM conditions, or that opts into the full requirements, is treated as a full-scope UK AIFM.
Dataset of UK AIFMs
Core attributes
• 100% Firm Coverage: Comprehensive list of all 1,272 authorised and registered UK AIFMs.
• AIFM Classification: Segmentation of firms by regulatory class as Full-Scope, Small Authorised and Small Registered.
• Permitted Activities: Permissions held across AIFMD, UCITS & MiFID, plus S21 approver status and MiFID client types.
• Governance Structure: Visibility of leadership structure & depth through count of Senior Management Function roles.
• Company Structure: Company registration ID, legal form, incorporation & authorisation dates, region & key financials.
