New requirements for private placement information reporting: Directors, supervisors, and senior management information included in regulatory scope

Recently, the Asset Management Reporting Platform (hereinafter referred to as the “AMBERS System”) of the China Securities Investment Fund Industry Association (hereinafter referred to as the “CSIA”) and the Personnel Management Platform have been updated again, with new requirements added for reporting information on directors and supervisors of private fund managers. Previously, only senior management and investment personnel information needed to be reported; now, it has officially entered a new stage where directors, supervisors, and senior management, as well as investment personnel, are fully included in regulatory oversight.

The relevant page of the AMBERS System displays a prompt: According to Article 47 of the “Measures for the Filing and Registration of Private Investment Funds,” when a private fund manager undergoes certain material changes, it shall complete the change procedures with the association within 10 working days from the date of the change. If your organization experiences changes in directors or supervisors, please complete the relevant major change procedures on the Asset Management Comprehensive Reporting Platform, and then promptly log in to the Personnel Management Platform to update the relevant personnel information.

It is understood that during the actual reporting process, first, relevant information about directors and supervisors must be entered into the Personnel Management Platform. After completing the entry, the directors and supervisors need to log in with their personal accounts to confirm the information. Once the information about directors and supervisors is successfully entered, it will automatically synchronize to the AMBERS System.

In addition, the CSIA’s public information page for private fund managers has also added a “Director and Supervisor Information” section, including their names, positions, and other details.

Industry insiders say that including information on directors and supervisors of private fund managers within the scope of regulation is an important institutional arrangement to improve corporate governance of private fund companies and strengthen investor protection. This expansion of information reporting, together with the “Measures for the Supervision and Administration of Private Investment Fund Information Disclosure,” creates a systemic synergy, upgrading regulation from “regulating institutions” to “regulating individuals” and “regulating behaviors.”

In February this year, the China Securities Regulatory Commission (CSRC) issued the “Measures for the Supervision and Administration of Private Investment Fund Information Disclosure” (hereinafter referred to as the “Disclosure Measures”), which will take effect from September 1, 2026. The “Disclosure Measures” consist of seven chapters and 44 articles, systematically regulating aspects such as basic information disclosure requirements, periodic reports, interim reports, liquidation reports, information disclosure management, supervision, and legal responsibilities.

In recent years, the private market has shown a continuous expansion trend. According to the latest data from the CSIA, as of the end of March 2026, there were 19,067 existing private fund managers, managing 140,931 funds with a total scale of 22.72 trillion yuan, setting a new record for six consecutive months. In terms of filing pace, 2,368 new private funds were filed in March, with a new filing scale of 227.2k yuan, surpassing 100 billion yuan for two consecutive months.

As the industry rapidly expands, regulatory efforts have also deepened and become more concrete. For example, standardized templates for CRS data reporting, quarterly and annual financial monitoring reports, and other data submission requirements introduced from 2024 have significantly improved the standardization and transparency of industry data.

Meanwhile, the CSIA has increased efforts to crack down on various violations related to improper reporting by private institutions. Recently, the CSIA disclosed six disciplinary decisions issued to private fund managers, three of which involved violations related to information reporting.

Among them, Zhejiang Yinuo was deregistered as a manager by the CSIA for submitting false information and failing to fulfill reporting obligations as required.

On one hand, some investors in Zhejiang Yinuo’s products are funds controlled by the company’s legal representative, Qiao Zhongxing, with related personnel holding the shares on his behalf. On the other hand, in November 2021, Zhejiang Yinuo’s affiliated company, Hangzhou Huijie Enterprise Management Consulting Partnership (Limited Partnership) (hereinafter “Hangzhou Huijie”), was established. Zhejiang Yinuo failed to report related information about the affiliated party in a timely manner to the association until May 20, 2025, when it completed the update of related party information on the Asset Management Business Comprehensive Reporting Platform.

Hangzhou Tianyu, which is associated with Zhejiang Yinuo, was also deregistered for providing false registration and filing information and for having senior management personnel who did not meet the requirements. According to the disciplinary decision, the registered shareholders Fan Moumou and Zhao Moumou in Hangzhou Tianyu’s business registration system are actually held by natural person Qiao Zhongxing. Additionally, some product investors’ funds originate from funds controlled by Qiao Zhongxing, with related personnel holding the funds on his behalf. The compliance and risk control officer registered in the Asset Management Business Comprehensive Reporting Platform, Zhang Chenjia, left the company in October 2024, and as of August 2025, Hangzhou Tianyu had no new compliance or risk control officers. According to Hangzhou Tianyu, Wu Moumou is currently responsible for some compliance and risk control work but also serves as an investment manager.

Furthermore, Beige Private Fund was also deregistered for providing false information and failing to cooperate with self-discipline inspections.

Specifically, Beige Private Fund registered as a private securities investment fund manager with the association on April 21, 2025. According to the registration information, the company’s general manager, Zhang Zhenwu, previously served as an investment manager and investment director at a certain company from June 2012 to March 2018. However, the company issued an official certificate to the Hubei Securities Regulatory Bureau stating that “since the company’s establishment, the employee roster confirms that this person has never been employed there.” Additionally, the association repeatedly assigned self-discipline inspection tasks to Beige Private Fund and its senior management, informing them of the requirements and interview deadlines for cooperation, but the relevant personnel failed to cooperate as required.