Investors often rely on what they see at first glance – attractive charts, tables of historical returns, and professionally designed web presentations. However, the Czech National Bank (CNB) has sent a clear signal in its new Supervisory Statement No. 3/2026: the era when websites served primarily as a polished marketing window is over. For high-net-worth individuals and expats with investments in Funds of Qualified Investors (FQI), this means a fundamental shift: the website is becoming an official supervisory document, and every word on it is subject to regulatory scrutiny.
This stricter perspective from the CNB, supported by the Czech Capital Market Association (AKAT), targets the discrepancy between what funds promise in their advertisements and what their statutes actually contain. If a fund’s website is full of optimism but omits a detailed asset breakdown or specific risks, it risks sanctions and forced corrections that could shake investor confidence.
Why is the CNB Tightening the Rules Now?
The regulator is responding to the increasing complexity of investment structures, particularly in alternative funds and FQIs. Many funds previously relied on the assumption that their website was merely a supplementary information channel. However, the CNB plans a major follow-up investigation in the fourth quarter of 2026 to verify whether online information complies with EU Regulation 2019/1156 on cross-border distribution and the actual risk profile of the portfolio.
A key point of contention currently being addressed by AKAT is the level of detail regarding asset composition. For you as an investor, this is vital news: if a fund refuses to transparently show exactly where your money is invested, or if the information on the website is too vague, it could be a red flag. Regulation is now pushing for a state where the investor receives the same hard data on the website as they would find in an in-depth audit.
“The CNB’s supervisory statement effectively turns fund websites into legally binding documents. Any discrepancy between marketing promises and the reality on the web will no longer be just an ethical issue, but a regulatory failure.”
Distinguishing Marketing Optimism from Reality
In this new environment, it is essential for wealthy investors to change how they evaluate information. The CNB expects funds to conduct their own internal audits of information obligations by autumn 2026. This is the ideal time for you to review your current positions with your advisors and verify the transparency of your investments.
As part of our professional oversight, we focus on whether the technical provider or fund manager truly communicates risks in their full scope. It’s not about reading thousand-page reports, but about ensuring that “marketing language” does not overshadow facts about leverage or asset liquidity. Aisa International, as your independent partner, ensures that your financial plan is not built on foundations that the regulator may soon label as insufficient.
Steps to Protect Your Investments
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Verify Information Consistency: Ask for a comparison between what the fund declares on its website and the information in its Key Information Document (KID) or fund statute.
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Monitor Portfolio Transparency: If a fund does not provide sufficient detail on its asset composition, ask why – the CNB will demand this level of detail much more strictly from Q4 2026.
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Look for Red Flags: Any mismatch between “promised returns” and “stated risk” on the fund’s website will be under scrutiny.
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Act Before Autumn: Do not wait for the results of the CNB’s investigation. Review your positions in FQIs and alternative funds now while managers still have time to make corrections.
While funds are currently debating whether these rules apply to local offerings or sub-threshold managers, you should be clear on one thing: transparency is the best insurance against future liquidity or valuation issues. A critical look at attractive web presentations is now a mandatory tool for every prudent investor.
FAQ: 5 Questions on CNB Oversight of Fund Websites
1. Why is the CNB interested in fund websites? The regulator wants to ensure that online information is not misleading and that investors are not lured by marketing promises that do not match the fund’s actual risk profile.
2. Does this tightening also apply to Funds of Qualified Investors (FQI)? Yes, it is in the FQI sector where the greatest pressure for more detailed disclosure of asset composition is expected.
3. What happens if a fund fails to correct its information by Q4 2026? The CNB plans to conduct follow-up investigations. Funds that do not meet information obligations risk sanctions and being forced to immediately adjust their public communication.
4. Can this regulation affect my investment returns? Not directly, but administrative compliance costs and potential changes in marketing strategies may have an indirect impact. The main benefit for you, however, is increased security and transparency.
5. How does Aisa International help in this matter? As part of our oversight, we monitor fund communications and alert clients to discrepancies that could signal future regulatory problems with their investments.
