Saudi Arabia's Capital Market Authority has opened a public consultation on draft amendments that would rewrite what the kingdom's investment funds must tell their unitholders, and where they must tell them. The regulator called upon interested persons and participants in the capital market to comment on changes to the Investment Funds Regulations, the Real Estate Investment Funds Regulations and the Glossary of Defined Terms, in a notice published on 18 October 2026. The consultation runs for 30 calendar days.
The draft pulls continuing disclosure and announcement obligations, currently spread across the rulebook, into a single place in the regulations. It would require annual and periodic reports to set out the dividends distributed to unitholders together with the sources and nature of those cash distributions, a change aimed squarely at funds that pay out of asset sales rather than operating income. Reports would also have to list a fund's top 10 investments, naming the asset type, the counterparty and the percentage of net asset value each represents.
Real estate funds face a further layer. Under the draft they would disclose the revenue of each property asset, that asset's share of net asset value, and the sectoral distribution of the portfolio. Annual reports for public funds would carry a performance analysis against the benchmark index, the factors behind that performance, future performance expectations and a risk assessment report. Separately, the draft makes the Saudi Exchange website the mandatory primary channel for fund disclosure, with publication on additional websites permitted alongside it.
For boards and executives, the significance sits less in any single line item than in the shift of burden. A requirement to explain the source of a distribution removes the ability to present a one off disposal gain and a recurring rental yield as the same number. Fund managers who have leaned on headline yield as a distribution story will find that story becomes auditable. Our inference is that this compresses the gap between the best and the worst disclosed funds in the market, and that the adjustment cost falls hardest on managers whose reporting systems cannot currently separate income by source at portfolio level.
The practical work starts before any final rule. Asset managers and real estate fund sponsors should map which of their existing reports already carry asset level revenue, counterparty names and net asset value percentages, and treat the gaps as a systems question rather than a drafting one. Counterparty naming is the item worth stress testing with legal and commercial teams, because confidentiality arrangements written for a lighter disclosure regime may not survive it. Institutional allocators should expect a richer comparison set and prepare to use it, since standardised top holdings and benchmark analysis make manager selection a quantitative exercise in places where it has been a relationship one.
The consultation itself is the near term decision point. A draft out for comment is not a rule, and the regulator has said comments will be considered for the purpose of approving the final proposed draft, which means the templates and definitions are still movable. Boards should decide now whether they want to be a voice in that process or a recipient of its outcome.
