SystemInvestment Compliance & Surveillance

Regulatory Change Management

Regulatory change management that maps every rule change to the funds, policies and owners it hits, cited to the paragraph

Each rule change mapped to the funds, policies and owners it hits, cited to its paragraph.

See one case, screen by screen ↓
demo486fundstested against one French-only circular: 14 sub-funds in scope, every exclusion cited to its paragraph
demo485of 486applicability calls confirmed by a second agent; a person decided the one it disputed
demo1.6daysmedian from publication to triage, against a 5-business-day target
target0missed datesevery dependent action re-planned when a regulator moves a date
In short

What is Regulatory Change Management?

Regulatory change management is the work of capturing every new rule, guidance and date change from regulators, deciding what applies to the firm, and making sure each obligation reaches the funds, policies, coded compliance rules and owners it affects, with evidence of who decided what. Regulatory Change Management is regulatory change management software for asset managers: seven AI agents read each regulator in its own language and cite every line to its paragraph, while Legal approves applicability, owners attest and the CCO signs.

AI in asset management: a buyer's guide to agentic AI for investment managers →

Updated

The problem

Why the regulatory change management process still runs on email and spreadsheets

Regulatory change management at a global asset manager starts with hundreds of regulator publications a month from the SEC, FINRA, CFTC, DOL, FCA, ESMA and a dozen national regulators, many published only in the regulator's own language. An analyst reads alert emails and vendor summaries and marks each item relevant or not in a spreadsheet. For the relevant ones, someone emails Legal to ask which funds it touches, the fund list is pulled from the fund administrator by hand, and policy owners are sent the circular and asked to assess impact. The compliance-rule coders hear late, often from a breach.

Then the dates move. The Form PF amendments' compliance date has moved four times, now to July 1, 2027, and a spreadsheet nobody re-plans goes stale. A French-only circular is read days late, a fund is ruled out and nobody re-checks it, a policy is updated but the coded rule is not. When an examiner asks who decided what, on which text, the answer is spread across email.

typical4movesof the Form PF amendments' compliance date, now July 1, 2027
demo318publicationsfrom 64 regulator sources in 30 days at the sample firm
demo99of 318not published in English
Where a relevant publication's working days goestimated
By hand20 days
With the solution2.8 days
  • Capturing it, and getting a local-language text read3 → 0.1 d
  • Triage: relevant or not, with a reason2 → 0.5 d
  • Working out which funds and entities it applies to5 → 0.5 d
  • Policy owners assessing impact and drafting redlines5 → 1 d
  • Briefing the rule coders and testing the coded rule3 → 0.5 d
  • Assigning owners and due dates, and re-planning moved dates2 → 0.2 d

Estimated split for one relevant publication at a multi-domicile fund manager, by hand and with the solution.

How it works

How a regulator publication reaches its owners

Seven agents read every regulator in its own language and map each paragraph to funds, policies and owners; Legal approves.

What comes in
Regulators and systems of record64 regulator sources, the fund master · plus policies and coded rules
Agents at work
Watcher agentreads every source
Reader agentEnglish beside
Then
Applicability agenttests every fund
Impact agentredlines, rule changes
Then
Checker agentre-tests every call
Then
Owner agentowners, due dates
Register agentregister, summary
A person decides
Change manager, Legal, owners, CCOpropose, approve, attest, sign
What comes out
Impact map
Owned actions
Signed summary
One case, step by step

One French-only circular, from capture to owned and attested actions

Quillfield Capital runs 486 funds and sub-funds in 11 legal entities and 9 domiciles. On Friday, October 16, 2026, Luxembourg's CSSF publishes Circular 26/918 on liquidity stress testing and AIFMD II liquidity management tools, in French only. Here is what happens next, screen by screen, in the working solution.

  1. 01Tuesday, 9:02 a.m.

    Six things need her, in order

    Priya Raman · Regulatory change manager

    Overnight the agents read 11 publications and opened 2 changes. Priya's home shows 318 publications in the last 30 days, 23 awaiting triage against a 5-business-day SLA, 186 open changes and 1,124 open actions, 3 of them overdue and escalated to Marcus Bell. First in line is the CSSF circular, where the Checker agent disagrees on one fund.

    Checker agent: “I agree on 485 of 486 calls. I disagree on Private Credit Evergreen … I put it at 71%; please decide.”

  2. 02The publications queue

    Every publication, in its own language

    Watcher agent

    The Watcher agent reads every source daily in the original language and sets the English title beside it: a BaFin interpretive decision on sustainability-related fund names, an AMF FAQ on SFDR, an SFC FAQ on dual-counter ETFs. Each carries a relevance score. 254 were ruled not relevant, each with a reason, and 20 a week are sample-checked by an analyst.

    “BaFin website timed out at 6:00 a.m. Two German-language publications may be waiting. The Watcher agent retries at 10:00 a.m.”

  3. 03Friday, 6:12 p.m.

    A French-only circular, English beside every paragraph

    Watcher and Reader agents

    The CSSF published the circular at 4:24 p.m.: 22 pages, French only. The Watcher agent captured it at 6:12 p.m. and opened change RC-2026-0418, and the Reader agent aligned English beside all 31 paragraphs, extracted 9 obligations and found the application date, March 31, 2027 (¶29). The impact map fans each paragraph out to the funds, policies, coded rule and owners it hits, each line labeled with its due date.

    ¶12, in English beside the French: “Managers run liquidity stress tests at least once a quarter for each fund, including a reverse scenario …”

  4. 046:31 p.m.

    486 funds tested, and she asks why the money market funds are out

    Applicability agent

    Against the fund master, 468 funds fall outside ¶5 because no Luxembourg-authorized manager runs them. Of the 18 Luxembourg funds, 14 sub-funds holding $49.3 billion are in scope and 4 are out: two money market funds (¶3), a closed-ended private equity fund (¶4) and a sub-fund that merges on November 30, 2026, before the application date (¶29). Priya asks the agents why the money market funds are out, and the answer quotes the French.

    Applicability agent: “Euro Liquidity and USD Liquidity are money market funds under Regulation (EU) 2017/1131, and ¶3 excludes them … The Checker agent agreed on both.”

  5. 056:52 p.m.

    The one fund the agents disagree on

    Checker agent

    The Checker agent re-tests all 486 calls with a separate model and agrees on 485. Private Credit Evergreen deals quarterly after a 24-month lock-up. The Applicability agent says open-ended and in scope at 92%, because investors can redeem before liquidation. The Checker puts it at 71%, citing the lock-up, the 5% dealing limit in the offering memorandum and ¶4's exclusion of closed-ended AIFs.

    Checker agent: “I would not decide this alone.”

  6. 06Tuesday morning

    She decides it, with a reason, and proposes to Legal

    Priya Raman · Regulatory change manager

    Priya reads both arguments beside their sources, offering memorandum §8.2 and the EU definition of an open-ended AIF, and rules the fund in scope: “redemption rights before liquidation make it open-ended (¶5)”. Her reason goes to Legal with the proposal: 14 sub-funds in scope, 472 out, 2 policies and 1 coded rule. Acting as herself, she cannot approve it.

    “Legal approves; you cannot approve your own proposal.”

  7. 07Approved

    Legal approves, and four owners get dated actions

    Eleanor Whitcombe · General Counsel

    Eleanor approves applicability with her reason: supported by ¶3, ¶4, ¶5 and ¶29. The Owner agent sends 5 actions to 4 owners from the responsibility map: Sophie Laurent's liquidity risk policy redline and first quarterly stress tests, Luc Reinert's liquidity management tools policy, Tomás Herrera's coded rule and Anne-Marie Weber's board paper for the management company. Policy due dates are the application date minus 33 days, the rule minus 16.

    “5 actions sent to 4 owners · due March 31, 2027”

  8. 08The redline

    Send her the redline, not the circular

    Impact agent

    The Impact agent searched 212 policies and 3,940 coded rules and traced ¶12 to §5.3 of the Liquidity Risk Management Policy – Luxembourg (LRM-LU v4.2). Its tracked changes move stress tests from semi-annually to once a quarter, add a reverse stress test that finds the redemption level at which a sub-fund can no longer meet requests, and report results to the board each quarter. Each insertion cites its paragraph; Sophie accepts, edits or rejects it with a reason.

    Nothing changes in the policy library or the compliance engine until the owners act.

  9. 09Before go-live

    The coded rule, tested in the sandbox first

    Tomás Herrera · Compliance rule coding lead

    Rule LQ-LU-117 goes from live version 7 to a version 8 drafted by the Impact agent: quarterly instead of semi-annual, a reverse scenario required, quarterly board reporting, and a scope of 14 sub-funds, 12 UCITS and 2 open-ended AIFs. Tomás runs it on Q3 2026 data in the compliance engine's sandbox: 13 pass and 1 alert, as expected, because Private Credit Evergreen has no reverse test on file yet.

    “The engine keeps its own maker-checker: a second coder approves v8 before go-live.”

  10. 10Attestation

    Done means proven, with the evidence attached

    Sophie Laurent · Head of Risk, Luxembourg

    Sophie's attestation has three steps: read the redline, attach evidence, attest. She links the published LRM-LU v4.3 and the board minutes of March 4, 2027 from the policy library, and the Checker agent confirms the published version matches the accepted redline. When she attests, action A-0418-1 closes and the evidence is kept 7 years.

    Checker agent: “published v4.3 matches the accepted redline” — 3 of 3 insertions present, no other changes.

Who it’s for

Built for everyone who owns a rule change.

One circular, seen by the five people who carry it — what they said they needed, and what their work looks like now.

PR
Priya RamanRegulatory Change Manager · London · proposes applicability
Regulatory change manager
Before
“I don't need more alerts. I need to know which of our 486 funds a French circular actually touches, and who owns the fix.”
Now
Opens an impact map already tested against all 486 funds, decides the one call the agents dispute, and proposes it to Legal with her reason.
EW
Eleanor WhitcombeGeneral Counsel · New York · approves applicability
General Counsel
Before
“Show me the paragraph. If the agent says a fund is out of scope, show me why, and show me who checked.”
Now
Sees every fund's tests with the excluding paragraph, both agents' arguments and the change manager's reason, then approves or rejects with her own.
MB
Marcus BellChief Compliance Officer · New York · approves extensions, signs
Chief Compliance Officer
Before
“I sign that every change was assessed and every deadline is owned. I want that to be true.”
Now
Signs a quarterly summary the Register agent drafted, every figure linked to the register, after the change manager marks it reviewed; approves every extension.
SL
Sophie LaurentHead of Risk, Luxembourg management company · policy owner
Policy owner
Before
“Send me the redline, not the circular. And tell me the date the board needs it.”
Now
Gets tracked changes to §5.3 cited to ¶12, due February 26, 2027, and attests with the published policy and the board minutes.
TH
Tomás HerreraCompliance Rule Coding Lead · New York
Rule owner
Before
Hears about a rule change late, often from a breach, and codes it from the circular.
Now
Receives the parameter change for LQ-LU-117 already drafted, tests it in the sandbox and sends it to the compliance engine for a second coder.
Built on the engine

7 agents. Each with one job, and hard limits.

Seven agents read every regulator in its own language and map each paragraph to funds, policies and owners; Legal approves.

Watcher agent

Reads 64 regulator and standard-setter sources daily in the original language, from regulator websites and feeds, the Federal Register, official journals and the law-firm memo inbox; dedupes, classifies each publication (final rule, proposal, guidance, Q&A, consultation, enforcement, date change) and detects moved dates.

  • Never marks an item not relevant without a reason
  • Below 85% relevance confidence, an analyst decides
  • Never decides applicability
Reader agent

Aligns English beside every paragraph of the original and extracts obligations, scope clauses, exclusions and dates, using a translation memory and a glossary of regulator terms in French, German, Italian, Spanish, Dutch, Chinese and Japanese.

  • Never shows English without the original beside it
  • Never paraphrases a legal term without the original
Applicability agent

Tests every fund and entity against the firm's own fund master, entity register and prospectus library: domicile, manager authorization, wrapper, open- or closed-ended, money market status, strategy, investor type and lifecycle.

  • Never rules out a fund without citing the excluding paragraph
  • Below 85% confidence, a person decides the fund
Impact agent

Runs the regulatory impact assessment: maps each obligation to the policies, procedures and coded compliance rules it hits, drafts tracked-change policy redlines and the rule's parameter change, and readies the rule for a test in the compliance engine's sandbox.

  • Never changes a published policy or a live rule
Owner agent

Assigns owners from the responsibility map, sets due dates from the application date minus buffers, reminds at 14 and 3 days, escalates to the CCO one day overdue, and re-plans every dependent action when a regulator moves a date.

  • Never extends a date: the CCO approves extensions
  • Always tells the old and the new owner when it reassigns
Checker agent

Independently re-tests every applicability call, including every “not applicable”, with a separate prompt and model; verifies every citation matches its source passage and every redline insertion matches its paragraph.

  • Never resolves a disagreement itself: a person decides
Register agent

Keeps the change and obligations register current, computes the program's measures, and drafts the quarterly CCO summary, board papers and the evidence pack for auditors and regulators.

  • Never signs
  • Never sends anything to the board
Change manager, Legal, owners, CCO

Propose, approve, attest, sign. The agents propose; a named person decides.

Ask in plain words

Ask the agents about any rule change, in plain words

Ask about a publication, fund, paragraph, policy or deadline, or tell the agents what to do. Every answer cites the regulator's paragraph or the system it came from, and every action waits for a person.

Which of our funds does the CSSF circular hit?

Fourteen Luxembourg sub-funds, $49.3 billion: twelve UCITS and two open-ended AIFs (¶5). Out: two money market funds (¶3), Private Equity Europe IV (¶4) and Japan Value Equity, which merges before March 31, 2027.

Why is Private Credit Evergreen disputed?

It deals quarterly after a 24-month lock-up. The Applicability agent reads that as open-ended; the Checker agent flagged it because the lock-up is long and ¶4 excludes closed-ended AIFs. A person should decide.

Which deadlines moved this year?

The Form PF amendments moved for the fourth time, now July 1, 2027, and Names Rule reporting on Form N-PORT is November 17, 2027 for our fund group. The 12 Form PF actions are re-planned and wait for your OK.

Draft the board paper for the management company

Drafted a two-page paper: what ¶12 and ¶17 require, the two policy redlines, the 14 sub-funds affected and the dates. It is attached to action A-0418-4 for Anne-Marie Weber.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

TodayThe regulatory change manager's home: publications read, triage waiting against the SLA, open changes and actions, what needs her next, and the agents' overnight thread with an ask box.
The impact mapThe regulatory impact assessment for a CSSF circular in French with English beside each paragraph, fanning out to every fund in scope, every fund ruled out, the policies, the coded rule and the owners, each line with its paragraph and due date.
The agents' run and the conversationEvery agent step with its timing and sources, and a conversation about the change where each answer cites the paragraph and actions wait for a person.
Regulatory horizon scanningEvery publication from 64 regulator sources in its original language with the English title, filters by regulator, language and type, relevance scores, and a source that timed out.
One fund's applicability testThe four tests from the circular's own paragraphs, the fund master record, and both agents' arguments where they disagree, with buttons for a person to rule in or out.
A person decidesThe change manager rules the disputed fund in scope with a required reason, kept in the audit trail and sent to Legal with the proposal.
Approved by LegalApplicability approved by the General Counsel, the decision strip complete, and five dated actions sent to four owners.
Policy redlinesTracked changes to the liquidity risk management policy, each insertion cited to its paragraph, for the owner to accept, edit or reject with a reason.
The coded rule changeLive and proposed parameters of a coded compliance rule, each cited to the circular, tested in the compliance engine's sandbox before it is sent.
Owner attestationA guided attestation: the redline, the published policy and board minutes as evidence, and the second agent's check that the published version matches.
Horizon and moved datesApplication and compliance dates for the next 20 months, the Form PF date history with its four moves, and the re-plan of 12 dependent actions waiting for approval.
The quarterly CCO summaryQ3 2026 drafted by the Register agent from the change register and audit trail, every figure linked, waiting for the change manager's review and then the CCO's signature.
Thresholds and rulesConfidence thresholds, the triage SLA, due-date buffers, reminders, escalation and approvals, each change needing a second approver.
Governance

Regulatory change management on the record: cited, approved, signed.

Every line cites the regulator's paragraphEvery impact line, fund test and redline cites the original paragraph, in the regulator's own language. English is shown beside the original, never instead of it.
The proposer never approvesThe regulatory change manager proposes applicability and Legal approves or rejects it with a reason. Acting as the proposer, the approve button is locked.
A second agent re-tests every callThe Checker agent re-tests every applicability call, including every “not applicable”, with a separate model. Disagreements, and any call below 85% confidence, go to a person.
No live policy or rule changes by an agentRedlines are drafts until the owner accepts them. Rule changes are tested in the compliance engine's sandbox and queued, and a second coder approves them in the engine before go-live.
Owners attest; the CCO signsOwners attest completion with evidence that the Checker agent matches to the accepted redline. The CCO approves extensions, never past the application date, and signs the quarterly summary the change manager prepared.
An audit trail an examiner can followWho did what, when, why and on which evidence, for every person and agent step with its version: append-only, kept 7 years, exportable as an evidence pack with a signed manifest. Settings changes need a second approver.
Configuration

Your regulatory change management rules, not ours

Thresholds, due-date buffers, reminders and approvals are settings. Every change needs a second approver and is logged.

SettingDefaultChoose from
Relevance confidence85%Set by the administrator with a second approver · below it, an analyst decides relevance
Applicability confidence85%Set with a second approver (the CCO) · below it, a person decides the fund
Checker re-test100% of callsEvery call, including every “not applicable”
Triage SLA5 business daysFrom capture to relevant or not
Policy due dateApplication date − 33 daysLeaves time for board approval
Coded rule due dateApplication date − 16 daysLeaves time for the sandbox and a second coder
Reminders and escalation14 and 3 days before due · 1 day overdue to the CCOBy email and chat, then weekly
ExtensionsCCO approvesNever past the application date
Connections

Works with the sources and systems your compliance program already runs on

Regulator sources64 sources read daily: SEC, FINRA, CFTC, DOL, FCA, ESMA, CSSF, Central Bank of Ireland, BaFin, AMF, CONSOB, CNMV, AFM, MAS, SFC, FSA Japan, the Federal Register and the Official Journal
Fund master and entity registerfrom the fund administrator: 486 funds, 11 legal entities, 9 domiciles, with licenses and regulators
Policy library212 policies and procedures with versions; changes arrive as draft versions
Compliance engine3,940 coded pre- and post-trade rules: read, sandbox tests and queued changes
Document managementprospectuses, offering memoranda and board minutes
Responsibility map, HR directory and GRC toolowners and delegates, email and chat reminders, and obligations and controls kept in step both ways
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
5days
to triage every relevant publication, in any language
Todayweeks for local-language items
With agents5 days
target
100%
of applicability calls re-tested by a second agent and decided by Legal
486 of 486 funds
each call re-tested
target
0missed dates
every action re-planned when a regulator moves a date; Form PF's moved four times
4 moves
Form PF, 2025 to 2027

“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (SEC and CFTC, Form PF compliance date extended to July 1, 2027 on Aug 31, 2026, its fourth move). AIFMD II (Directive (EU) 2024/927) is real; CSSF Circular 26/918 and its text are illustrative. Quillfield Capital, its funds and the people named on this page are fictional: characters and sample data in the working solution.

Questions

What compliance and legal teams ask us.

What is regulatory change management?

Regulatory change management is the work of capturing every new rule, guidance and date change from regulators, deciding what applies to the firm, and making sure each obligation reaches the funds, policies, coded compliance rules and owners it affects, with evidence of who decided what. Regulatory Change Management is regulatory change management software for asset managers: seven AI agents read each regulator in its own language and cite every line to its paragraph, while Legal approves applicability, owners attest and the CCO signs.

What is regulatory horizon scanning, and how does it work here?

Regulatory horizon scanning is watching regulators for what is coming and when, and turning each publication into regulatory intelligence the firm can act on. The Watcher agent reads 64 sources daily in the original language, classifies each publication, merges duplicates and checks every source for moved dates. The Horizon screen shows application and compliance dates for the next 20 months, with the history of every date a regulator has moved.

How does it decide which funds a rule change applies to?

The Applicability agent tests every fund against your own fund master: domicile, manager authorization, wrapper, open- or closed-ended, money market status, strategy, investor type and lifecycle. It never rules a fund out without citing the excluding paragraph. A second agent re-tests every call, the regulatory change manager decides any disagreement and proposes, and Legal approves.

Can it read regulator publications that are not in English?

Yes. In the sample firm's last 30 days, 99 of 318 publications were not in English: French, German, Chinese, Japanese, Italian, Spanish and Dutch. The Reader agent sets English beside every paragraph of the original, and every impact line is cited to the original paragraph, not to a summary.

What happens when a regulator extends a compliance date, like Form PF?

The Watcher agent detects the move, and the Owner agent re-plans every dependent action to keep the same buffers before the new date. After the Form PF compliance date extension to July 1, 2027, its fourth move, 12 actions were re-planned and waited for the change manager's OK before owners were asked to confirm. The full date history stays on the change.

Does it keep a compliance obligations register?

Yes. The Reader agent extracts each publication's obligations, obligations mapping links each one to the funds, policies, coded rules and owners it hits, and the change register holds every open change from capture to attestation with its regulator, entity, stage, funds, actions, owners and due date, searchable and exportable. Obligations and controls stay in step with your GRC tool both ways.

With AI regulatory change management, do people stay in control, and can the AI change our policies or rules?

People decide. The agents never change a published policy or a live coded rule: redlines are drafts the owner accepts, and rule changes are tested in the sandbox and approved by a second coder in your compliance engine. The change manager proposes and Legal approves applicability, owners attest with evidence, and the CCO approves extensions and signs the quarterly summary.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents, and it goes live once every quality gate has passed. Setup connects your regulator sources, imports the fund master, the policy library and the coded rules, maps owners, then re-runs last month's publications so you can compare the agents' calls with what your team decided by hand.

See it on
your regulators.

We'll run Regulatory Change Management on a sample of your own recent regulator publications and your fund list.