The 2025 Global Investment Performance Standards (GIPS®) Conference delivered critical updates about the evolving landscape of performance reporting and compliance. Key discussions focused on GIPS standards enhancements, the SEC Marketing Rule FAQs, and emerging best practices in attribution, private fund reporting, ethics, and leadership. The CFA Institute also reaffirmed its commitment to driving adoption of the GIPS Standards among OCIO firms and asset owners.
GIPS Standards Updates
Several important changes were announced, including new guidance and tools designed to strengthen transparency and comparability:
- Guidance Statement for OCIO Portfolios (Effective December 31, 2025)
Establishes a standardized framework for OCIO performance reporting, improving consistency across strategies.
- Verifier Standards (Effective January 1, 2026)
Introduces requirements for verifying asset owners and fiduciary management providers (FMPs) to UK pension schemes, reinforcing independence and disclosure principles.
- Composites for Fiduciary Management Providers (Effective January 1, 2026)
Clarifies scheme classification and mandates retroactive application of changes, disclosure of composite assignment updates, and enhanced reporting for unconstrained composites.
Additional updates included trademark guidelines and new tools and resources. Insights from the September 2024 GIPS Standards Asset Owner Performance Survey revealed that 68% of respondents require or inquire about GIPS compliance for liquid assets, compared to 8% for illiquid assets.
Upcoming Guidance and Tools
Several key resources and guidance documents are on the horizon to help firms navigate evolving best practices and policy considerations.
- Exposure Draft: Best Practices for Return Attribution Reporting (Comment period ends December 12, 2025)
Provides recommendations, not official guidance, on attribution reporting.
- Trade Error Guidance Statement (In development)
Will address when portfolios should be removed from composites due to material trade errors, disclosure requirements, and definitions of materiality.
- Whitepaper: Considerations for Trade Error Policies (In development)
Offers practical insights for firms developing trade error policies.
Important: Exposure drafts and white papers are only recommendations. Firms are not required to adopt them for GIPS compliance. Official guidance statements, such as the OCIO Portfolios guidance and forthcoming trade error guidance, must be followed once effective.
What’s Next? CFA Poll Results
The CFA polled conference participants to understand what future guidance they should prioritize. The results ranked priorities for future guidance as follows:
- 34% Performance-based fees and fee transparency
- 26% Alternatives
- 23% After-tax reporting
- 16% Private wealth
Existing Considerations: SEC Marketing Rule
Three years post-adoption, the SEC Marketing Rule continues to pose challenges with performance presentation, hypothetical returns, and predecessor performance. Key takeaways from the conference include:
- Performance must be presented net of fees.
- Hypothetical performance requires robust policies and clear disclosures.
- Predecessor performance demands detailed documentation.
- FAQs released in March 2024 provided relief for extracted performance and characteristics.
The SEC’s exam priorities for 2025 indicate that firms should also focus on consistent disclosures, fee accuracy, and risk/conflict policies.
Why It Matters
These updates underscore the importance of proactive compliance and transparent performance reporting. Firms should review their current practices against existing and upcoming guidance and regulations to ensure readiness and reach out to experienced experts if additional assistance is needed.
ACA Can Help
ACA’s Performance Services team empowers investment managers to optimize performance, streamline operations, and meet evolving regulatory and investor demands. We offer a comprehensive suite of advisory and managed services designed to address complex challenges across investment performance, data analytics, regulatory compliance, and investor reporting.
Our advisory solutions include GIPS compliance consulting and verification, regulatory performance advertising guidance, and performance attestations, ensuring firms stay ahead of industry standards and regulatory expectations.
ACA’s Managed Performance Services deliver scalable, outsourced support for performance calculations, data analytics, and reporting infrastructure, helping firms enhance efficiency and reduce operational risk.
With a dedicated team of over 80 investment performance professionals, ACA delivers tailored solutions across asset classes and geographies, driving measurable impact and strategic advantage for our clients.