External Research in Portfolio Management: What Has Applied Since 1 September 2026?
Broker research, market reports provided by custodian banks and analyses from specialised providers form part of the investment process for many asset management companies.
Since 1 September 2026, amended provisions of the Liechtenstein Asset Management Act (VVG) and Asset Management Ordinance (VVO) concerning research and analyses have been in force.
For asset management companies in Liechtenstein, the key practical question is:
Which external information qualifies as relevant research – and what does this mean for payment, governance and control?
Not Every Market Comment Is Research
The concept of research includes analyses relating to financial instruments, issuers, markets or investment strategies where they provide relevant information and added value for investment decisions.
Trading comments and customised trading advice directly connected with the execution of a specific transaction are expressly excluded.
This distinction is important in practice.
Where an asset management company bases its investment decisions on its own research, the specific regime for third-party research does not apply merely because internal research is carried out.
It becomes relevant in particular where external research that can be used for investment decisions is added to the process.
A report from a custodian bank or broker concerning securities, issuers or markets may therefore qualify as research where it feeds into investment decisions – even if it is used solely internally.
By contrast, a trader's comment directly linked to the execution of a specific order is excluded.
Greater Flexibility in Paying for Research
One of the key changes concerns the remuneration of external research.
Joint payment for execution and research is now possible, and the previous EUR 1 billion threshold no longer applies.
At the same time, the payment model is subject to requirements concerning the agreement with the provider, client information and the management of conflicts of interest.
Other payment models remain available.
Third-party research may, for example, be paid for from the asset management company's own resources.
A separate research payment account is also possible, subject to specific requirements relating to fees, budgeting, controls and oversight.
The reform therefore does not simply represent deregulation. It provides greater flexibility in how research is paid for, while maintaining corresponding governance and transparency requirements.
Research Must Demonstrate Its Value
The ongoing quality assessment is particularly relevant from a governance perspective.
The quality, usability and value of third-party research must be reviewed annually.
The assessment should also consider the extent to which the research contributes to better investment decisions.
Solid objective criteria should be used, with remedial action where deficiencies are identified.
The annual assessment also remains relevant where research is obtained from independent providers that do not provide execution services.
Research therefore becomes not only a procurement issue, but also part of the investment governance framework.
Special Case: Issuer-Sponsored Research
Issuer-sponsored research is also expressly addressed.
Research must be fair, clear, not misleading and identifiable as research.
Specific requirements apply for material to qualify as “issuer-sponsored research”; other issuer-paid material must be identified as a marketing communication.
What Should Asset Management Companies Review?
From a practical perspective, it is worth reviewing:
- Which external research sources are actually used in investment decisions?
- Which information qualifies as research and which is merely execution-related trading commentary?
- How is third-party research paid for?
- Are client disclosures and conflict-of-interest arrangements consistent with the chosen payment model?
- Is there a documented annual assessment of research quality, usability and value?
These are not an additional FMA checklist, but practical questions arising directly from the research regime in force since 1 September 2026.
Conclusion
For asset management companies in Liechtenstein, the reform primarily brings two developments:
greater flexibility in obtaining and paying for external research, combined with clearer requirements for governance and quality assessment.
The relevant question is therefore not only which research is used, but also:
How does it enter the investment process, how is it paid for, and what actual value does it add to investment decisions?
Peak Compliance AG specialises in Compliance and Risk Management outsourcing solutions for asset managers and managers of collective assets in Switzerland and Liechtenstein.
Status: October 2026.
