disclosure regimes
The rules that make the measurement possible — and the ones that do not
Everything Kanonstone publishes rests on a handful of disclosure obligations, and on their dates. These pages set out what each one requires, what it makes readable by a machine and at what granularity, and what it leaves out of reach. Every date has been read in its primary text.
The short version, and it is not the comfortable one: under current law there is no public European source that would allow this measurement to be reproduced in Europe. ESAP centralises what is already public and creates no new obligation; neither AIFMD II nor ELTIF 2.0 puts portfolio positions in front of anyone but investors and regulators. What is missing in Europe is not a search interface — it is a position-level disclosure duty.
United States
When private loan schedules became machine readable
The rule that made a cross-lender comparison possible at all
The SEC required business development companies to tag their financial statements, including every schedule set out in Article 12 of Regulation S-X, in Inline XBRL — with each amount tagged separately. Compliance ran from 1 August 2022 for funds eligible to file a short-form registration statement, and from 1 February 2023 for all others.
Who decides that a loan is level 3
A private standard, and the rule that gives it force
ASC 820 is issued by the Financial Accounting Standards Board, a private standard-setter. It binds SEC registrants through 17 CFR 210.4-01(a)(1), which presumes financial statements not prepared in accordance with generally accepted accounting principles to be misleading or inaccurate.
What Form N-PORT discloses, and what it withholds
Position-level data, published once a quarter — and not by BDCs
Business development companies do not file Form N-PORT. Rule 30b1-9 applies to registered management investment companies and to exchange-traded funds organised as unit investment trusts, excluding money market funds and small business investment companies registered on Form N-5.
European Union
What ESAP will make measurable in Europe, and when
A single access point that creates no new disclosure
ESAP was established by Regulation (EU) 2023/2859 of 13 December 2023. Article 1(1) requires ESMA to establish and operate it by 10 July 2027. It centralises information already made public under the Union acts listed in its Annex; it creates no new publication obligation.
What European private credit funds must disclose, and to whom
To the regulator, to investors, and — very little — to the public
Under Article 23(4)(d) of Directive 2011/61/EU as amended, a manager must periodically disclose the composition of its originated loan portfolio to investors. That disclosure is made to investors, not to the public.
these pages describe what the texts say · they are not legal advice, and the official text always governs · where a primary source could not be read, the point has been left out rather than paraphrased