UCITS reports must flag regulated-market securities

Managers of Estonian public funds, including pension funds, present each fund's securities portfolio in the investment report — part of the annual and half-yearly package alongside the accounting report and the transaction-and-brokerage-fee report — showing every investment and its share of net asset value. For a eurofond, the portfolio presentation must separately identify or distinguish securities admitted to trading on the regulated securities market (reguleeritud turg)Riigiteataja named in Investeerimisfondide seadus § 107(1)(1)–(2)Riigiteataja, in the § 103(1)(1) sense of transferable securitiesRiigiteataja. That requirement sits in § 6(3) of Finance Minister Regulation No 8 of 18 January 2017Riigiteataja (in force since 23 January 2017, made under Investeerimisfondide seadus § 83(7)Riigiteataja). The regulation applies to every public fund formed or founded under the Investment Funds ActRiigiteataja, with each contractual sub-fund reported separately.

Alongside it, funds other than those in § 6(3) distinguish three groups in the portfolio presentation: securities whose price cannot be fixed exactly and reliably on a market or other price basis, securities priced with a valuation system independent of the issuer, and securities whose price or value is permanently available to the market; mandatory pension-fund reports further break out investments in the manager's other funds and group, related-issuer securities, fund-of-funds by type, material value changes, and regulated-market versus non-regulated-market debt with explanations of material changes, impairments, valuation method and risk impact where debt is illiquid; accounting follows IFRS with the NAV-determination order and Annex 1 adjustments; and eurofond and alternative-fund reports carry the SFT and AIFMD add-ons. Fund accountants should therefore keep the full package as is and apply the market distinction on the eurofond securities line: tag each holding against the regulated-market definition the provision points at, confirm prospectus and rules references point at the right market definition, and keep the pension-fund and non-UCITS breakdowns as the regulation states them.

Legal basis: Rahandusministri määrus nr 8 of 18 January 2017, Nõuded avalikustamisele kuuluvate fondi aruannetele, § 6(3), made under Investeerimisfondide seadus § 83(7), referring to §§ 103(1)(1) and 107(1)(1)–(2). (The documents state the 2017 adoption and entry into force; no separate entry-into-force date for a recorded version is stated in them.)