Global Reporting Principles Implementation Timeline

			Release 1 (2024)	Release 2 (2026)	Release 3 (Date TBD)
M1	Investment Management Costs	Private disclosure	Identify gaps in total investment cost capture and reporting Report total fund and asset class: Base management fees gross of offsets Performance fees on either an accrual or paid basis Underlying base fees Underlying performance fees on either an accrual or paid basis Attribute all internal asset management costs to asset classes Report costs by implementation style (e.g., internal/external, passive/active, etc.) Estimate missing asset management costs Report within three months of your year-end	Everything in Release 1 Report: Performance fees on accrual basis Underlying performance fees on accrual basis	Everything in Release 2 Report: All non-invoiced asset management and transaction costs incurred inside investment vehicles All underlying costs Implicit bid/ask spreads for fixed income Explicit transaction costs Estimate missing transaction costs
		Public disclosure	Disclose total fund and asset class asset management costs and transaction costs (as a % of assets) Disclose total fund internal operating expenses, base fees, and performance fees Report prior year costs Explain whether reported costs comply with the above Disclose estimates and the basis of estimates	Everything in Release 1 NB: Explain whether reported costs comply with the above	Everything in Release 2 NB: Explain whether reported costs comply with the above
M2	Pension Administration Costs	Private disclosure	Report total pension administration costs (per active member and annuitant) Provide a breakdown of material administration costs Report within three months of your year-end	Not necessary	Not necessary
		Public disclosure	Same as private disclosure (above) Report prior year costs	Not necessary	Not necessary

1. We will recommend implementation objectives before 2026.

2. On July 1, 2025, the following changes were made to the Module ‘M1’ for private disclosures.

Scoring for performance fees on an accrual basis different from cash basis was added to Release 2.
Including transaction costs in the private reporting was moved from Release 2 to Release 3 based on the feedback from clients.