Key Takeaway

• Document your role and chapter decision (Firm/Asset Owner/dual-role) before building anything.
• Lock the complying entity boundary so your claim matches how you’re held out.
• Establish core policies: valuation, performance calculation, report preparation, retention.
• Implement proof of delivery: distribution logs (prospects) or oversight delivery evidence (asset owners).
• Decide verification strategy (now vs later) and design for readiness even if you verify later.

Before you build composites, before you write reports, before you start arguing about templates—pause.

GIPS implementation is not primarily a documentation exercise. It’s a credibility system. And systems fail when the foundations are vague.

This checklist is designed to be used as a “greenlight gate.” If you can’t confidently tick each box, don’t rush forward. Fix the foundation first.

Check 1: Your GIPS role is explicitly documented (Firm vs Asset Owner vs both)

This is where most teams quietly lose months.

You need a written statement answering:

• Are we presenting performance as a manager (Firm), as an asset owner, or both depending on audience?
• If both, what performance presentations fall under each role?

This check directly reflects the GIPS 2020 structure: separate frameworks exist because the standards are tailored to different presentation contexts.

Minimum evidence:

A one-page scope memo signed off by performance + compliance + business leadership.

Check 2: Your “complying entity” boundary makes sense to the market

GIPS doesn’t tolerate artificial boundaries.

For firms, compliance is firm-wide; you cannot claim compliance for a composite or a product in isolation.

So define the entity in a way that matches how you are held out—especially if you have multiple subsidiaries, shared branding, or shared investment teams.

Ask these questions:

• Would a prospect reasonably interpret our claim as covering more than the entity we defined?
• Does our website/pitch material present us as one manager?
• Do we share personnel, policies, and processes across entities?

Minimum evidence:

A documented firm definition (or asset owner definition) and the rationale.

Check 3: You have written policies for valuation, performance calculation, and report preparation

This is not a “nice to have.” It’s the operating engine.

Even professional commentary on the 2020 standards highlights the expectation that firms disclose that policies for valuing investments, calculating performance, and preparing GIPS Reports are available upon request—because those policies must exist.

Minimum evidence:

A policies-and-procedures manual (even if version 1.0 is lean), covering:

• valuation sources and hierarchy
• fee treatment
• cash flow handling
• return calculation method and frequency
• error correction approach
• report controls and approvals

Check 4: You can evidence report distribution (or oversight-body delivery)

This is where “compliance” stops being internal.

If you are a firm, report distribution expectations are embedded in the standards—such as providing updated composite reports at least once every 12 months to prospects who remain prospects, and making every reasonable effort to provide reports to required recipients in applicable contexts.

If you are an asset owner, your reporting obligation is typically to your oversight body, and you must be able to demonstrate how the GIPS Asset Owner Report was provided to that body.

Minimum evidence:

A simple distribution log process (CRM note, email archive convention, portal download tracking, or board pack archive) that proves:

• what was delivered
• to whom
• when
• which version

Check 5: Your verification strategy is explicit—even if the answer is “later”

Verification is not required to claim compliance, but it is a recognized independent third-party service intended to provide additional confidence in the claim, and it carries expectations around verifier qualification and independence.

If you leave verification undecided, teams tend to under-build evidence trails and over-trust memory.

Minimum evidence:

A one-paragraph decision statement:

• Are we pursuing verification in the next 12–24 months?
• If yes, who owns verifier selection and readiness?
• If no, what triggers a re-evaluation?

The “if you only do one thing” version of the checklist

If you want the leanest version:

1. Document whether you are acting as Firm, Asset Owner, or both.
2. Lock the entity boundary in a way that matches how you’re held out (firm compliance is entity-wide).
3. Write the core policies (valuation, performance calculation, reporting controls).
4. Implement proof of delivery (prospects or oversight body).
5. Decide verification timing and build readiness discipline accordingly.

Next, we’ll stitch everything you’ve done so far into a simple, practical readiness roadmap—so you can move from “we think we’re in the right chapter” to “we’re actually ready to make a claim and support it.”

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