# First Sentier Investors (UK) IM Limited

> First Sentier Investors (UK) IM Limited is an SEC-registered investment advisory firm in Edinburgh, United Kingdom, registered since 2015, reporting over $5 billion in regulatory assets under management in its Form ADV filing dated March 31, 2026.

- CRD: 281323
- Filed as: FIRST SENTIER INVESTORS (UK) IM LIMITED
- Also doing business as: FSSA, STEWART INVESTORS
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Edinburgh, United Kingdom
- Filing period: October 2026
- Form ADV filing dated: March 31, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/281323
- AdvisorCensus page: https://advisorcensus.com/firm/first-sentier-investors-uk-im-limited-edinburgh-281323

## Quick answers

**How is First Sentier Investors (UK) IM Limited compensated?**
On its Form ADV (Item 5.E, October 2026), First Sentier Investors (UK) IM Limited reports these compensation arrangements: a percentage of assets under its management. The amounts are in Item 5 of its Form ADV Part 2A brochure.

**Where is First Sentier Investors (UK) IM Limited located?**
First Sentier Investors (UK) IM Limited's principal office is in Edinburgh, United Kingdom, according to its Form ADV; the April 2026 filing also lists 1 other office (Schedule D, Section 1.F).

**Is First Sentier Investors (UK) IM Limited registered with the SEC or a state?**
First Sentier Investors (UK) IM Limited is an SEC-registered investment advisory firm, registered since 2015. Status as filed: Approved. CRD 281323.

**How much does First Sentier Investors (UK) IM Limited manage?**
First Sentier Investors (UK) IM Limited reports $13,271,630,276 in regulatory assets under management in its Form ADV filing dated March 31, 2026 (100% discretionary).

**How have First Sentier Investors (UK) IM Limited's assets and staff changed since 2021?**
In the Form ADV data for First Sentier Investors (UK) IM Limited: Regulatory assets under management: $22,218,104,017 in the October 2021 data and $13,271,630,276 in the October 2026 data, down 40%. Total employees: 362 in October 2021 and 314 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does First Sentier Investors (UK) IM Limited serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (21); investment companies (2); sovereign wealth funds and foreign official institutions (1).

**Does First Sentier Investors (UK) IM Limited report any disciplinary disclosures?**
Reports 6 disclosure items on Form ADV Item 11: yes answers to 11.C(2) (SEC or CFTC finding of a violation), 11.C(4) (SEC or CFTC order), 11.D(1) (another regulator's finding of a false statement or omission, or of dishonest, unfair, or unethical conduct), 11.D(2) (another regulator's finding of a violation), 11.D(4) (another regulator's order in the past ten years), and 11.H(1)(c) (regulator's civil action dismissed under a settlement). Each question covers the firm and its advisory affiliates, and one event can produce several yes answers. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/281323

**What changed in First Sentier Investors (UK) IM Limited's recent Form ADV filings?**
In the April 2026 filing data: Added the business name Fssa. Employees performing advisory functions went from 63 to 50. Regulatory assets under management went from $17,969,990,043 to $13,271,630,276 (-26%). Updated its list of owners and control persons (Schedule A).

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management

### Regulatory assets under management (Item 5.F)
- Total: $13,271,630,276
- Discretionary: $13,271,630,276
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Investment companies | 2 | $342,642,772 |
| Pooled investment vehicles (other than investment companies and business development companies) | 21 | $12,759,270,525 |
| Sovereign wealth funds and foreign official institutions | 1 | $169,716,979 |

### Advisory services (Item 5.G)
- Portfolio management for pooled investment vehicles (other than investment companies)
- Portfolio management for businesses (other than small businesses) or institutional clients

### Firm details
- Registered since: 2015 (11 years)
- Employees: 314 total, 50 performing advisory functions
- Wrap fee program participation: No
- Disclosures (Item 11): Reports 6 disclosure items on Form ADV Item 11.

### Item 11 questions answered yes
- 11.C(2): Has the SEC or the CFTC ever found that the firm or an advisory affiliate was involved in a violation of SEC or CFTC regulations or statutes?
- 11.C(4): Has the SEC or the CFTC ever entered an order against the firm or an advisory affiliate in connection with investment-related activity?
- 11.D(1): Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?
- 11.D(2): Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate was involved in a violation of investment-related regulations or statutes?
- 11.D(4): In the past ten years, has another federal regulator, a state regulator, or a foreign financial regulator entered an order against the firm or an advisory affiliate in connection with investment-related activity?
- 11.H(1)(c): Has a domestic or foreign court ever dismissed, under a settlement agreement, an investment-related civil action brought against the firm or an advisory affiliate by a state or foreign financial regulator?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. The detail of each yes answer is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/281323

### Other offices (Schedule D, Section 1.F), as of the April 2026 filing
- London

### Websites listed on Form ADV (Item 1.I)
- [firstsentiergroup.com](https://firstsentiergroup.com)

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $22,218,104,017 | 362 | March 25, 2021 |
| October 2022 | $27,148,802,626 | 378 | March 31, 2022 |
| October 2023 | $20,833,901,993 | 377 | August 28, 2023 |
| October 2024 | $18,741,005,242 | 368 | March 14, 2024 |
| October 2025 | $17,969,990,043 | 344 | July 29, 2025 |
| October 2026 | $13,271,630,276 | 314 | March 31, 2026 |

Regulatory assets under management: $22,218,104,017 in the October 2021 data and $13,271,630,276 in the October 2026 data, down 40%.
Total employees: 362 in October 2021 and 314 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Added the business name Fssa.
- Employees performing advisory functions went from 63 to 50.
- Regulatory assets under management went from $17,969,990,043 to $13,271,630,276 (-26%).
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. First Sentier Investors (UK) IM Limited (CRD 281323): Form ADV filing data as of October 2026.
