Reserved Investor Fund (RIF) Regime

Introduction

The Reserved Investor Fund (RIF) regime is a special tax framework for UK-based unauthorised contractual co-ownership schemes aimed at professional and institutional investors. If you operate such a scheme, you'll need to make an entry notification to join the regime, submit regular accounting period information, and notify HMRC of certain changes within strict time limits.

What is a Reserved Investor Fund?

A Reserved Investor Fund is a UK-based unauthorised contractual scheme for co-ownership arrangements that meet specific qualifying conditions. The regime is designed for professional and institutional investors, not retail investors.

The rules are set out in The Co-ownership Contractual Schemes (Tax) Regulations 2025 (SI 2025/200). To operate as a RIF, your scheme must meet several qualifying conditions relating to its structure, investor base, and investments.

Entering the RIF regime

If your scheme meets the qualifying conditions on the date it starts operating as a RIF, you can enter the regime by making an entry notification to HMRC.

What you need to provide

To complete an entry notification, you'll need:

• Scheme details, including the scheme operator's Corporation Tax Unique Taxpayer Reference (if available)
• Start date and accounting period end date
• Business name and address of the operator

You must confirm that the scheme:

• Is a co-ownership scheme
• Is an Alternative Investment Fund
• Limits participation to professional or large investors
• Is UK-based
• Meets the restriction and ownership requirements

You'll need to specify how the scheme meets the ownership requirement and which restriction conditions the scheme or any sub-schemes meet.

Treating conditions as met

If your scheme is treating either the ownership requirement or the UK property-rich condition as met (before they are actually met), you must confirm which conditions are being treated as met and provide the names of any sub-schemes relying on this treatment.

You must also confirm that the scheme or sub-schemes intend and reasonably expect to meet the requirements within 12 months, and that you have taken or will take steps to achieve this. Details of these steps must be provided.

Submitting your entry notification

From 6 April 2026, you must make entry notifications using HMRC's online service. You'll need to sign in using Government Gateway details (which you can create if you don't have them) or an email address. You can save your progress and return later.

If you're an agent or manager completing the form on behalf of the scheme operator, you'll need to upload form 64-8 or a letter of authority.

HMRC aims to process entry notifications within 15 working days.

Ongoing reporting requirements

Once operating as a RIF, you must submit accounting period information to HMRC within 6 months after the end of each accounting period.

Information about participants and units

You'll need to complete and upload the 'Participants and units in the scheme' template, which must include:

• Name of the RIF or any sub-schemes
• Names and addresses of all participants in the scheme
• Number and classes of units held by each participant at the end of the accounting period
• Amount of income per unit for each class

If a participant left the scheme before the period ended, you must still provide their name and address, with their number of units marked as 0 (zero). The template has two tabs that both must be completed.

The uploaded file must not exceed 10MB and must be in XLSX format. You can also upload supporting documents up to 10MB in PDF, JPEG, XLSX, DOCX, or PPTX format.

Reporting breaches of requirements

You must report any breaches of the ownership requirement or restriction requirement during the period, including:

• Which condition was breached and the date of the breach
• Whether the breach was rectified and the date of rectification
• The date of any deemed disposals

You must also report breaches from earlier periods that were rectified during the current period.

For the restriction requirement, you need to specify which restriction conditions were met by the RIF or any sub-schemes at any time during the accounting period.

If the fund or any sub-scheme met the exempt investor condition, you must confirm that all participants were exempt from tax on gains and that the operator has taken steps to monitor this exemption.

UK property-rich schemes

If your RIF or any sub-schemes met or were treated as meeting the UK property-rich condition, additional reporting requirements apply.

For an umbrella fund with sub-schemes meeting the UK property-rich condition, you must complete the 'UK property-rich umbrella' template if any sub-scheme made disposals or any participants disposed of units during the period.

For a single RIF meeting the UK property-rich condition, you must provide the total value of all disposals made during the period and the difference between total gains and losses. If participants disposed of units, you must also complete the 'UK property-rich RIF' template.

If your RIF or sub-scheme stopped meeting the UK property-rich condition during the period but then met the non-UK property assets condition, you must confirm there was a deemed disposal and provide the date.

Submitting accounting period information

From 6 April 2026, you must submit accounting period information using HMRC's online service. The same sign-in requirements apply as for entry notifications. HMRC aims to process reports within 15 working days.

Notifying HMRC of changes

Operators of a RIF must notify HMRC of certain changes as required by Part 2 of The Co-ownership Contractual Schemes (Tax) Regulations 2025.

Changes requiring notification

You must notify HMRC when the scheme:

• Decides to exit the regime (an exit notice)
• Breaches one or more qualifying conditions and stops being a RIF
• Has breached the ownership requirement and no longer expects to rectify the breach within 9 months
• Has breached the restriction requirement and no longer expects to rectify the breach within 9 months
• Has been treating the ownership requirement as met but no longer expects to meet it within the initial 12-month period
• Has been treating the UK property-rich condition as met but no longer expects to meet it within the initial 12-month period
• Changes the restriction condition that the RIF or a sub-scheme is relying on
• Is an umbrella scheme that establishes a new sub-scheme or winds up an existing sub-scheme

Time limits for notifications

You must make notifications within the time limits for each type of change. This is usually within 30 days of the change happening, though in some cases it's within 30 days of the scheme operator becoming aware of the change.

The specific time limits for each change are detailed in section 6 of the tax rules for the Reserved Investor Fund (RIF) technical note published by HMRC.

Submitting change notifications

From 6 April 2026, you must make change notifications using HMRC's online service. The same sign-in and agent authorisation requirements apply as for entry notifications. HMRC aims to process change notifications within 15 working days.

Getting help

If you need to update your contact details, need help completing any notification or return, or have any RIF-related queries, you can email cisc.sheffield@hmrc.gov.uk (include 'RIF' in the subject line).

If you cannot use the online service, contact HMRC's Collective Investment Scheme Centre.

Sources

• Submit an entry notification for a Reserved Investor Fund
• Submit accounting period information for a Reserved Investor Fund
• Notify HMRC of a change to a Reserved Investor Fund

This article provides general guidance based on current HMRC rules. For advice specific to your situation, speak to your accountant.