The Principles for Responsible Investment’s 2026 Transparency Reporting window closes July 29. As signatories ourselves and consultants to private fund managers across the alternative asset space, we’ve seen a familiar pattern play out every reporting cycle: Firms assume the process will be easier than it is, start later than they should and find themselves scrambling in the final stretch.
This year, the framework has changed extensively. Signatories to the Principles for Responsible Investment, or PRI, will respond to a maximum of 39 indicators this year, compared to a maximum of 257 in previous years. That reduction might sound like a relief until signatories realize what is underneath it: mandatory requirements where voluntary ones previously existed, written response fields included for nearly every indicator, and a structural reorganization of how asset classes are reported.
Several of the most consequential changes are hiding in plain sight, and the firms most at risk of missing the reporting deadline are those that assume logic from prior years will hold up in 2026.
What’s actually changed and why it matters
The intent behind many of the framework updates is to allow signatories to more easily describe their responsible investment-related practices and to clarify their static responses by using the new text fields. As signatories prepare to report, we have noticed that important changes have been overlooked. Below are the most frequently missed changes and guidance for how to navigate them:
- Different portions of the report will be public. What has changed?
- Answer: The organizational profiling questions, which contain detailed information on a signatory’s AUM and asset class breakdown, will no longer be public.
- Guidance: Signatories should be less wary about providing detailed asset-class breakdown information given the additional privacy afforded by the 2026 framework.
- PRI is changing its assessment thresholds. What do we know?
- Answer: The new, star score thresholds will not be available before the reporting window closes. Assessments are expected by the end of year and should follow a similar November timeline.
- Guidance: While we do not believe the thresholds will be the same as those used in the past, signatories can still perform self-assessments by calculating their percentage score at the firm- and asset-class levels.
- The new framework asks for examples. Do signatories have to include them?
- Answer: Signatories do not need to include examples when they are identified as voluntary, but they must include this data for indicators marked as mandatory. For mandatory examples PRI does not provide explicit guidance on what information must be included.
- Guidance: Signatories should avoid providing excessive details that are not requested when preparing examples. Be sure to anonymize examples and otherwise reduce identifying details unless the information being shared is already public.
- PRI removed the hedge fund asset category. Where should signatories allocate hedge fund assets?
- Answer: PRI’s guidance for signatories that operate hedge fund strategies or allocate investments to hedge fund managers is to allocate this AUM to other categories, based on the underlying asset classes.
- Guidance: For internally managed hedge funds, we recommend analyzing holdings at the security level to determine the relevant asset classes. For externally managed hedge funds, we recommend assigning asset class by strategy. For example, an allocation to a long/short equity manager should be classed as “listed equity,” while an allocation to a structured credit manager should be classed as “FI – securitized.”
- The “senior leadership statement” has been updated. What was this replaced with in the new framework, and who must sign it?
- Answer: The senior leadership statement has been renamed “the senior leadership accountability statement,” or SLA, and it largely mirrors the prior questions. Unlike in past years, the new indicators do not require acknowledgment or signature by a specific person.
- Guidance: Although signature is no longer required, the firm’s senior leaders should continue to review and sign off on the report.
- I have not started my PRI Report for 2026. What do I do?
It is not too late to prepare the 2026 report, and signatories that are just getting started should focus their efforts strategically. Below are a few best practices to help make the most of the remaining time.
- For existing signatories, check the change guide that PRI published earlier this year. This will help identify any prior responses and rationale that can be reasonably relied upon for this year.
- Read every question carefully. At first blush, the new indicators may appear simple, but small tweaks to language (e.g., the top-end response for density-based questions has shifted from “all” to “90-100%”) will have a big impact on how signatories can or should respond.
- Reach out to internal stakeholders now. Signatories need to ensure they can substantiate responses. Communicating the need for review and back-up now will help reduce friction in these final weeks.
A more detailed breakdown of the full 2026 framework, including key dates and a comparison of past and present indicators, is available here.
- My firm is ready to submit our 2026 PRI report, any final tips?
During the final review, we encourage firms to test their disclosures. Signatories should be able to positively respond to each of the following inquiries:
- Can the response to each indicator be substantiated? In the event of regulator or investor inquiry, is supporting documentation easily accessible?
- Do all responses align with existing disclosure related to a firm’s responsible investment practices, where applicable?
- Are any responses exaggerated, specifically density-based questions?
- Have relevant personnel reviewed and approved the report, including the SLA indicators?
With about a week before the deadline, signatories can and should make every effort to report. Keeping in mind the intent of the framework, to facilitate accurate, straightforward disclosure, will help signatories to not overcomplicate their responses.
Trysha Daskam-Smith is managing director and head of sustainability risk & strategy at Silver Regulatory Associates. Jarod Riedl is associate director at Silver Regulatory Associates.
Guest posts on ImpactAlpha represent the opinions of their authors and do not necessarily reflect the views of ImpactAlpha.
