There is a global shift among institutional investors and regulators toward greater fee transparency. That shift is being formalized in markets such as Australia, where recent regulatory changes seek to reduce distortions in fee disclosure arising from large, irregular costs. The changes echo broader regulatory scrutiny on misleading or opaque fee disclosure in other major markets globally.
Specifically, the Australian Securities and Investments Commission (ASIC) announced amendments to Regulatory Guide 97 (RG 97) on 1 May 2026. This Standard governs how superannuation funds and managed investment schemes disclose fees and costs to consumers.
As private market allocations continue to grow worldwide, regulations are evolving to ensure greater transparency. The challenges RG 97 seeks to address, such as opaque cost structures, are increasingly shared across pension systems globally.
The two key RG 97 amendments are: reducing one-off distortions associated with the cost of stamp duty1 and the disclosure of internally managed private credit, as summarized in this table:
Fig. 1: Amendments to RG 97
The amendments to RG 97 are intended to reduce distortion from large, irregular costs in disclosed fees, supporting greater alignment in superannuation fund disclosures.
All the same, the importance of taking a holistic view of fund performance is becoming more important for pension funds, both in Australia and globally. They’re increasingly encouraged to consider the full impact of fees, costs, and transaction‑related charges on long‑term net outcomes.
Across global markets, large pension funds, endowments, and sovereign investors are elevating fee validation from a periodic reporting requirement to an ongoing exercise. This is due to the growing scale and complexity of private market allocations, especially as retail investor access broadens.3
In the US, the SEC has repeatedly stated that protecting investors in private funds, including individual investors that invest directly through pension plans, endowments, and other pooled vehicles, is an important regulatory objective. Although SEC’s August 2023 adoption of the Private Fund Adviser Rules has since been vacated in June 2024,4 SEC has continued to emphasize the need for investor protection and transparency through existing regulations.
For instance, US SEC’s Marketing Rule (Rule 206(4)-1) continues to support investor protection in private funds by requiring that advisers’ marketing materials are fair and not misleading.5
Meanwhile in the UK, the Financial Conduct Authority’s Regulatory Priorities report for the wholesale buy-side sector continues to focus on the growth of private markets, which it believes should be underpinned by good governance and responsible practices.6 Initiatives include supervising firms’ approaches to risk management in private markets, as well as working with global standard-setting bodies to ensure that the UK agrees internationally on transparency and valuation.7 In this environment, the ability to normalize fee data and validate economic terms will increasingly become central to effective governance.
While disclosure frameworks vary by jurisdiction, regulators have consistently highlighted the need for clearer visibility into fees and valuation practices, especially in the reporting of net-of-fee outcomes.
As regulations evolve, institutional investors would benefit from fee validation and benchmarking data. eFront FAIR provides fee benchmarking against a large peer universe (3,000+ active funds), allowing LPs to compare management fees, expenses, and total fund economics across strategies and asset classes.
Importantly, eFront FAIR provides ongoing validation to capture how economic terms play out over time, rather than at a single reporting point. This helps LPs align terms embedded in limited partnership agreements and side letters, such as management fee bases, step‑downs, expense allocations, and carry mechanics. It also helps investors determine whether a manager’s performance meets fiduciary and governance expectations once all costs are accounted for.
In short, eFront FAIR helps trustees answer critical questions:
By validating fees against agreed fund terms, eFront FAIR helps investors maintain consistent oversight across portfolios. As disclosure requirements and data volumes expand, the embedded data accuracy is a critical benefit that supports credible reporting, including compliance with regulations like Australia’s RG 97.
Source
[1] https://www.asic.gov.au/regulatory-resources/find-a-document/regulatory-guides/rg-97-disclosing-fees-and-costs-in-pdss-and-periodic-statements
[2] https://www.asic.gov.au/regulatory-resources/find-a-document/consultations/cs-39-proposed-change-to-stamp-duty-disclosure-requirements
[3] https://www.asic.gov.au/about-asic/news-centre/find-a-media-release/2025-releases/25-164mr-asic-to-review-superannuation-investment-requirements
[4] https://www.sec.gov/files/iac-recommendation-private-market-assets-final-09182025.pdf
[5] https://www.sec.gov/files/ia-6383-fact-sheet.pdf
[6] https://www.sec.gov/files/ia-6383-fact-sheet.pdf
[7] https://www.fca.org.uk/publication/regulatory-priorities/wholesale-buy-side-report.pdf
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