Disclosure & Diligence Framework

A common structure for preliminary disclosure and the controlled transition into formal institutional diligence.

Purpose

Reduce interpretation burden while preserving the depth and independence of institutional diligence.

This overview describes the framework's intended scope. It is designed to support preparation and institutional dialogue before or during formal review without prescribing an investment outcome.

Document control

Draft for institutional dialogue and consultation.

Version: 0.1

Published: 10 August 2026

Owner: PMIJ Standards Programme

Consultation closes: 30 September 2026

Next review: Fourth quarter 2026

Revision history: 0.1 — initial publication

Institutional allocators, managers, advisors and specialist contributors may submit written comments. Please identify the framework code, relevant section and institutional perspective.

Submit a consultation comment

Framework scope

Preliminary disclosure structure

Present manager and fund information in a consistent order so reviewers can identify what is available and what requires clarification.

Manager, fund and strategy information
Team, governance and track-record evidence
Portfolio, risk and operational information
Legal, compliance and reporting materials

Information status and provenance

Distinguish statements, supporting records, third-party materials and information that remains subject to verification.

Source and date identification
Manager-confirmed and third-party information
Known limitations and outstanding evidence
Version control and update responsibility

Controlled diligence workflow

Support deeper review through defined requests, permissions and responses rather than uncontrolled document exchange.

Information-request ownership and status
Document permissions and access records
Responses, follow-up questions and escalation
Review continuity across institutional teams and advisors

Independent assessment

Preserve the reviewing institution's authority over scope, materiality, verification and decision-making.

Institution-specific diligence requirements
Independent legal, tax, operational and investment review
No presumption of completeness or suitability
No implication of approval or investor interest

Institutional boundary

Independent review remains with the institution.

This framework is not a certification or recommendation.

Use of the framework does not imply PMIJ endorsement, regulatory approval, suitability, investor interest or a positive investment conclusion. Managers remain responsible for their information. LPs and their advisors conduct their own diligence and make their own decisions.

Download framework overview