公开募集证券投资基金业绩比较基准指引与操作细则解读

Regulatory Framework - The China Securities Regulatory Commission (CSRC) issued the "Guidelines for Performance Comparison Benchmarks of Publicly Raised Securities Investment Funds" on January 23, 2026, which will take effect on March 1, 2026[1] - The guidelines consist of six chapters and twenty-one articles, emphasizing the serious and stable application of performance comparison benchmarks[2] Internal Control and Management - Fund managers are required to establish robust internal control mechanisms and management systems to ensure the stability of fund managers and investment styles[3] - The guidelines mandate that performance benchmarks must align with the core elements of the fund contract and investment style, and cannot be changed arbitrarily once selected[9] External Constraints and Supervision - The guidelines enhance external constraints by clarifying the supervisory responsibilities of fund custodians and regulating the behavior of fund sales and evaluation institutions regarding performance benchmarks[2] - Strict regulatory measures will be enforced by the CSRC against violations by fund managers, custodians, sales institutions, and evaluation agencies[10] Performance Benchmark Standards - The "Operational Guidelines" consist of six chapters and twenty-eight articles, detailing the standards for establishing performance benchmarks, which must be representative and sustainable[11] - Fund managers must regularly assess the rationality and potential risks of deviations from performance benchmarks, ensuring compliance and accountability[11] Industry Development Trends - The public fund industry is expected to focus on equity funds, with a need for repositioning in actively managed equity funds[12] - Future adjustments may include thematic funds covering multiple industries and multi-asset investment funds to diversify risks and enhance performance stability[13] Policy Implications - The guidelines support the high-quality development of public funds, addressing issues such as significant performance deviations from benchmarks in actively managed equity funds[12] - The government aims for publicly raised funds to increase their holdings of A-shares by at least 10% annually over the next three years[12]