From 1 November 2026, Chile’s pension funds face an annual ceiling on the fees they pay to the mutual funds, investment funds and other vehicles they invest in. The caps, set by the Superintendencia de Pensiones in a resolution issued on 4 March, are expressed as a percentage of each fund’s value: 0.56% for Fund A, 0.47% for Fund B, 0.35% for Fund C, 0.19% for Fund D and 0.12% for Fund E.
The rule implements the pension reform, Law 21.735. The total of these implicit fees charged to a pension fund may not exceed the limit, and if it does, “el exceso será de cargo de la administradora de fondos de pensiones”: the excess falls on the AFP, the management company, not on members’ savings. The caps apply until 31 March 2027, the last day of the current multifund system. On 1 April 2027 new generational funds begin, with fee ceilings of their own to be set later.
A budget for the whole fund
Chile already limits fees vehicle by vehicle. A joint resolution of the Superintendencia and the financial market regulator, the CMF, sets maximums for 1 July 2026 to 30 June 2027 of 2.40% for private equity and private debt vehicles, including co-investment, 1.69% for domestic real estate and infrastructure funds and 0.66% for developed and global equity ETFs. The new cap applies alongside those limits and works as a budget. A fund’s implicit fees in total, measured against its whole value, must fit under one number. A private equity sleeve priced near its vehicle maximum has to be paid for by cheaper holdings elsewhere in the same fund.
A second rule bites on vehicles with heavy Chilean exposure. For investments made since 1 April 2026, pension funds may not pay fees to vehicles that invest more than 10% in Chilean instruments, unless they invest preferentially in small and mid-sized local issuers, which must make up at least 80% of the vehicle’s assets. Regional or global vehicles escape the ban if their Chilean exposure is no more than 15%.
Where the pressure falls
Foreign managers carry most of the exposure. Superintendencia data to December 2020, published by the AFP association, put external management fees at 0.27% of assets under management, with 81% paid to foreign investment funds and index-tracking securities, 6% to foreign private equity and debt vehicles and 13% to domestic funds. A report cited by the AFP association put the share of portfolio delegated to outside managers at 87% for Fund A and 1% for Fund E. Figures for December 2020 compiled by RankiaPro show Fund A paying 0.49% of its assets in such fees and Fund D 0.19%, against caps now set at 0.56% and 0.19%.
On those figures the caps leave little room for fee growth just as the regulator allows for a potential increase in alternatives. The likely responses are familiar to anyone who has negotiated with a large limited partner: pressure on management fees, more co-investment, separately managed accounts in place of pooled funds, and passive ETFs where active managers cannot justify their price. Because any overrun is billed to the AFP, each AFP now has a direct financial reason to police the costs inside the funds it buys.
Why it matters for long-horizon owners
For sovereign funds and pension plans that invest alongside Chilean AFPs in global private equity and private debt funds, the cap puts a more fee-sensitive investor at the negotiating table, with a regulatory reason to ask for better terms.
The regulator argues the squeeze is manageable. It says it took account of the fees funds currently pay and of a potential increase in alternative assets, and that the levels “permitirán a las administradoras adecuar con alta flexibilidad sus portafolios”, given the headroom under the limit on alternatives. The caps also run only until the end of March, so the more durable test is the ceilings still to be set for the generational funds.
What to watch
- 31 March 2027: the current caps expire with the multifund system.
- 1 April 2027: generational funds begin, with fee ceilings based on their reference portfolios and permitted fluctuation bands.
- 30 June 2027: the current vehicle-level maximums lapse.
Sources
- Superintendencia de Pensiones emite resolución que modifica el Régimen de Inversión para incorporar la nueva regulación de las comisiones indirectas que se pagan con cargo a los Fondos de Pensiones, Superintendencia de Pensiones, 5 March 2026
- Superintendencia de Pensiones emite resolución que modifica el Régimen de Inversión (comunicado de prensa), Superintendencia de Pensiones, 5 March 2026
- Resolución Conjunta Superintendencia de Pensiones N° 38 y Comisión para el Mercado Financiero N° 6940, Superintendencia de Pensiones and CMF, 30 June 2026
- New Pension Fund Investment Regime: Restrictions and Aggregate Caps on Underlying Fund Fees, Alessandri, 2 April 2026
- Comisiones por gestión externa de fondos llegan a 0,27%, bajo el promedio de la OCDE, Asociación de AFP, 7 November 2022
- ¿Cuánto pagan las AFP chilenas en comisiones de gestión externa?, RankiaPro, 8 March 2023