Saudi regulator moves to force funds to disclose top 10 holdings

Summary

• Draft CMA rules would cut the fund disclosure threshold to 5% of net assets.
• Funds would also publish their ten largest investments, dividend sources and benchmark comparisons.
• Investors would gain a clearer view of what Saudi fund portfolios actually hold.

The latest

Saudi fund managers would have to disclose any position worth 5% or more of net asset value, under draft amendments the Capital Market Authority put out for public consultation on the Istitlaa platform. The 30-day window closes on 17 November 2026. The package covers the Investment Funds Regulations, the Real Estate Investment Funds Regulations and the glossary of terms used across the authority's rulebooks.

Details

• The threshold: The draft lowers the specified disclosure ratio to 5% of a fund's net asset value, under sub-paragraph 1 of paragraph (b) of Article 28. Positions at or above that line would have to be surfaced to investors rather than sitting inside aggregate portfolio figures.
• Top holdings: Funds would be required to disclose their ten largest investments, and for each one the asset type, the name of the counterparty, and the position's share of net assets. That is a far more granular picture than a headline allocation breakdown gives.
• Dividends: The proposal requires a breakdown of distributed profits and their sources, which would let investors see whether payouts are funded by income the portfolio actually generated or by other means. Distribution sourcing is a recurring question in income-focused and real estate funds.
• Benchmark test: Managers would have to publish an analysis of fund performance against the indicative benchmark, turning relative performance into a standing disclosure item rather than a marketing claim chosen by the manager.
• Where it is published: The draft makes the authority's website the mandatory primary channel for fund disclosures, consolidating filings in one official venue instead of leaving dissemination to each manager's own platforms.
• Scope: Three texts are being amended together: the Investment Funds Regulations, the Real Estate Investment Funds Regulations and the glossary of terms used in the authority's regulations and rules. Real estate funds therefore fall under the same disclosure upgrade as conventional funds.
• The timeline: The consultation runs 30 days and ends on 17 November 2026. The authority has not announced when a final version would be issued, nor a date on which any approved amendments would take effect.
• Status: This remains a draft. Nothing in the package binds fund managers until the authority adopts a final text, and provisions can change between consultation and approval.

Background

The Istitlaa platform is the government channel through which Saudi regulators publish draft rules for public comment before adoption. Consultation periods allow market participants, including fund managers and investors, to submit observations on proposed text.

Between the lines

Taken together, the three core items — a lower 5% threshold, named counterparties in the top ten holdings, and the source of distributions — point less at how much funds disclose than at what investors can verify independently. Centralising publication on the authority's own website makes those filings comparable across managers, which matters most where benchmark performance is in dispute.

What's next

Comments close on 17 November 2026. The next trackable signal is the authority's final text: whether the 5% threshold survives consultation, and what compliance date is set for managers of both conventional and real estate funds.

Source: Maaal, Al-Eqtisadiah, Al Arabiya, citing Saudi Capital Market Authority (Istitlaa platform)