As the first supporting administrative regulation under the Regulations on the Supervision and Administration of Private Investment Funds, the Measures elevate information disclosure oversight from "industry self-discipline" to "administrative regulation", introducing systematic new requirements regarding the content, frequency, and methods of disclosure. The main contents are as follows:

1. Clarification of Responsible Parties and Behavioral Norms

• The responsibilities of the three entities (the fund manager, custodians and sales agencies) in information disclosure:

The fund manager shall be the primary responsible party for information disclosure, and such liability can’t be exempted by delegating the task to another institution; the custodians shall conduct substantive review and verification of financial information including the fund’s net asset value and subscription, redemption prices. The custodians must issue a warning, facilitate corrections, and report the matter to the relevant authorities if any material errors are discovered; sales agencies shall not alter the information provided by the fund manager.

• Disclosure Methods: Fund managers shall disclose information to investors through agreed-upon non-public methods, such as mail, email, investor-specific websites, mobile applications, or other designated channels.
• Look-through Disclosure Requirements: where a private investment fund invests in other private investment funds, asset management products or invests through an SPV, it must disclose the investment path and the underlying assets. The invested institutions are obligated to cooperate in this process.

2. Establishment of Differentiated Disclosure Requirements Based on Fund Type

3. Obligation for Interim Reporting of Major Events

• For events that may have a significant impact on the rights and interests of investors, such as changes to the fund manager, custodian, portfolio manager, investment structure, major related-party transactions, disclosure must be made within 5 working days from the date the event occurs.

4. Establishment of an Information Disclosure Management System

• Private fund managers and custodians are required to establish an information disclosure management system and designate specific departments and senior management personnel to be responsible for information disclosure affairs.
• Private fund managers, custodians, sales agencies, and other service providers shall properly maintain documents and materials related to the information disclosure of the private investment fund. The retention period shall be no less than 20 years from the date of completion of the fund liquidation.

5. Transitional Arrangements

• For funds newly submitted for filing after September 1, 2026: Documents such as the fund contract shall comply with the relevant provisions of the Measures.
• For existing funds that were filed before September 1, 2026: If the fund contract is amended, the amended matters shall comply with the provisions of the Measures; if the fund contract is not amended, there is no immediate requirement to revise the fund contract.