The Spanish National Securities Market Commission (“CNMV”) has published Technical Guide 1/2026 on internal control in the management of closed-ended vehicles (the “Technical Guide”), dated 30 September 2026, setting out good practices and criteria relating to the organisational structure of management companies of closed ended vehicles, the establishment of internal policies, procedures and controls, and the identification and management of conflicts of interest. The Technical Guide operates as a “comply or explain” standard: entities departing from its criteria must be able, on the one hand, to demonstrate to the CNMV that they comply with their regulatory obligations and, on the other, to explain why they have departed from the criteria set out in the Technical Guide.
The Technical Guide responds to the marked increase in the number of management companies managing closed-ended vehicles, the wider variety of investment strategies now in use, and the extension of their marketing to retail investors — developments that have intensified the CNMV’s supervisory activity in this sector. The Technical Guide does not cover remuneration policy, as this is already addressed in the ESMA Guidelines.
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