The European Union directive known as UCITS - Undertakings for Collective Investment in Transferable Securities - continues to grow as the standard compliance model for investment funds in Asia.
According to a recent survey by RBC Dexia Investor Services, 62 per cent of Asian asset managers already manufactured or distributed UCITS, while another 12 per cent indicated they were planning to do so in the future.
Only 26 per cent of asset managers in Asia are not interested in this model.
UCITS has also gained ground in Latin America and Africa, while it is widely used in Europe for obvious reasons.
But the Investment and Financial Services Association continues to seek support for its proposal to create an Asia-Pacific fund passport, which is more flexible and would include property and infrastructure funds.
Yet, the narrow definition of the UCITS model is exactly why industries and regulators worldwide support it as a global standard.
"UCITS is really gaining ground as a de facto global standard because it is so prescriptive, whereas Australian managed investment schemes are probably a lot more flexible in terms of what you are allowed to do in them," Tria Investment Partners managing director Andrew Baker said.
"UCITS has really got a long way in Asia; it is one of the obstacles Australia has to face.
"It is all very well to get mutual recognition treaties with Hong Kong, but then there is the commercial reality of what structures do people actually want to buy."
Boutique fund manager backer Treasury Group has two funds, which are registered in Dublin, that make use of the UCITS model. Treasury Group executive director David Cooper said it had attracted much attention.
"It is just a very high-compliance fund, therefore pension funds like to use it," Cooper said.
But support for the adoption of this compliance model in Australia has been limited.
AMP Capital Investors managing director Stephen Dunne chooses his words carefully when asked whether he would support the adoption of UCITS here.
"I do think that there should be a greater harmonisation across the region," Dunne said.
"One of the [governement's] recommendations on how to improve Australia's participation in the region as a financial services hub is trying to get greater harmonisation between our products, in terms of structures, governance, regulations, so that they become more fundable across borders.
"I do think that would be a great step forward for us in terms of having a product that is exportable throughout the region. But I think there is more work to be done on that front."
