26 unchanged sentences
As of April 1, 2026 , 117 partners led the firm, with an average of over 20 years of investment or industry experience.
−Removed: As of March 31, 2025, we had approximately 1,130 total employees, including over 375 investment professionals and approximately 750 employees across our operating team and implementation teams dedicated to sourcing, executing, analyzing and monitoring private markets opportunities.
+Added: As of March 31, 2026, we had over 1,310 total employees, including approximately 420 investment professionals and approximately 890 employees across our operating team and implementation teams dedicated to sourcing, executing, analyzing and monitoring private markets opportunities.
We believe our scale and position in private markets provide us a distinct competitive advantage with our clients and fund managers.
1 unchanged sentence
This, in turn, helps us make better investment decisions and generate better returns, thereby attracting new clients and investment opportunities.
−Removed: During the year ended March 31, 2025, we reviewed over 4,000 investment opportunities and conducted approximately 5,600 meetings with fund managers across multiple geographies and all four asset classes.
+Added: During the year ended March 31, 2026, we reviewed over 4,700 investment opportunities and conducted over 5,700 meetings with fund managers across multiple geographies and all four asset classes.
During the last three years ended December 31, 2025, we allocated an average of $75 billion annually in capital to private markets on behalf of our clients, excluding legacy funds, feeder funds and research-only, non-advisory services.
19 unchanged sentences
Mandates for portfolio analytics and reporting services typically include licensed access to our proprietary performance monitoring software, SPI Reporting.
−Removed: We provided portfolio analytics and reporting on nearly $780 billion of client commitments through SPI Reporting as of March 31, 2025.
+Added: We provided portfolio analytics and reporting on over $900 billion of client commitments through SPI Reporting as of March 31, 2026.
Our Competitive Strengths
37 unchanged sentences
In many instances, existing clients have increased allocations to additional asset classes and commercial structures and deployed capital across our asset management and advisory services businesses.
−Removed: Our dedicated in-house business development, marketing and client relations teams, comprising approximately 200 professionals in offices across 15 countries, maintain an active and transparent dialogue with our diverse and global client base.
+Added: Our dedicated in-house business development, marketing and client relations teams, comprising over 230 professionals in offices across 16 countries, maintain an active and transparent dialogue with our diverse and global client base.
Consistent with our staffing model on the investment side, we ensure local clients are interfacing with business development professionals who have local expertise.
3 unchanged sentences
• SPI Research monitors investment opportunities and is used by our investment professionals as an investment decision making tool.
−Removed: As of March 31, 2025, SPI Research contained information on approximately 18,000 fund managers, 49,000 funds, 122,000 companies, and 273,000 investments .
+Added: As of March 31, 2026, SPI Research contained information on more than 19,000 fund managers, 52,000 funds, 139,000 companies, and 293,000 investments .
SPI Research initially augmented our own due diligence, investment and portfolio construction processes.
7 unchanged sentences
Data science within private markets has historically been difficult due to the lack of standardization and the labor-intensive process of collecting and processing information.
−Removed: We have a dedicated Data and Software Engineering team, which manages and continues to develop our SPI Research and SPI Reporting platforms (and our additional proprietary tools built on these platforms) and supports our efforts to be a market leader in an area that is essential to evaluating private markets.
−Removed: Strong Investment Performance Track Record
+Added: We have a dedicated Data Analytics & Technology Solutions (“DATS”) team, which manages and continues to develop our SPI Research and SPI Reporting platforms (and our additional proprietary tools built on these platforms) and supports our efforts to be a market leader in an area that is essential to evaluating private markets.
+Added: Investment Performance Track Record
We believe our track record is a key point of differentiation to our clients.
−Removed: As shown below, we have outperformed the MSCI ACWI Index, the benchmark index used for comparison across all of our investment strategies on an inception-to-date basis as of December 31, 2024.
+Added: The table below shows our performance summary by asset class as of December 31, 2025 .
See “Part II, Item 7.
Management’s Discussion and Analysis of Financial Condition and Results of Operations—Investment Performance” below for more information and explanatory footnotes.
−Removed: (in billions except percentages and multiples)
−Removed: Strategy Committed Capital Cumulative Invested Capital Realized Distributions NAV Total Gross IRR Net IRR Net Multiple of Invested Capital Net IRR versus Benchmark
−Removed: Primaries $ 325.9 $ 246.8 $ 164.3 $ 182.6 $ 346.9 11.2 % 10.8 % 1.4x 0.6 %
−Removed: Secondaries 28.4 23.7 11.9 21.7 33.6 17.5 % 14.4 % 1.3x 3.2 %
−Removed: Co-investments 55.6 53.1 28.3 54.2 82.5 15.6 % 12.6 % 1.4x 1.7 %
−Removed: Total $ 409.9 $ 323.6 $ 204.5 $ 258.5 $ 463.0 12.1 % 11.2 % 1.4x 0.9 %
−Removed: We attribute our strong investment performance track record to numerous factors, including our scale and global reach, our selective investment process powered by our technology and data advantage and our experienced investment teams.
+Added: PRIVATE EQUITY BUYOUT* VENTURE CAPITAL & GROWTH EQUITY REAL ESTATE INFRASTRUCTURE PRIVATE DEBT
+Added: INVESTMENT STRATEGY (1,3,4)
+Added: INVESTMENT STRATEGY (1,3,5)
+Added: INVESTMENT STRATEGY (1,3,6)
+Added: INVESTMENT STRATEGY (1,3,7)
+Added: INVESTMENT STRATEGY (1,3,9)
+Added: Primaries 14.1% Primaries 14.4% Core/core+ fund investments 6.8% Core/debt - all strategies 6.8% Primaries 7.8%
+Added: Secondaries 17.6% Secondaries 14.5% Value-add/opportunistic fund investments 7.9% Core+/value-add - primary fund investments 10.6% Direct lending 7.1%
+Added: Co-investments 16.2% Directs/co-investments 16.2% Real estate debt fund investments 5.1% Core+/value-add - secondary fund investments 8.1% Opportunistic 8.4%
+Added: Value-add/opportunistic secondaries & co-investments 9.0% Core+/value-add - co-investments (8)
+Added: 11.2% Co-investments/secondaries 9.5%
+Added: Direct lending 8.3%
+Added: Opportunistic 10.9%
+Added: Customized managed accounts (*)
+Added: We attribute our investment performance track record to numerous factors, including our scale and global reach, our selective investment process powered by our technology and data advantage and our experienced investment teams.
Together, these attributes allow us to source highly attractive investment opportunities with a compelling risk-adjusted return profile for our clients’ diverse investment objectives.
8 unchanged sentences
Our management and advisory fees grew from $285 million in fiscal 2021 to $926 million in fiscal 2026, representing a 27% compounded annual growth rate.
−Removed: We have had a high level of success in retaining our advisory clients with an approximately 95% retention rate since inception.
Highly predictable with strong visibility into near-term growth
2 unchanged sentences
As of March 31, 2026, we had 528 revenue-generating asset management and advisory programs and therefore are not dependent upon or concentrated in any single investment vehicle or client.
−Removed: For the year ended March 31, 2025, no single client contributed more than 5% of our total management and advisory fees, and our top 10 clients, which comprise over 60 separate mandates and commitments to commingled funds, contributed approximately 20% of our total management and advisory fees.
+Added: For the year ended March 31, 2026, no single client contributed more than 5% of our total management and advisory fees and two commingled funds each contributed more than 5% of our total incentive fees.
+Added: Our top 10 clients, which contribute to 65 separate mandates and commitments to commingled funds, comprise 17% of our total management and advisory fees.
Upside from performance fees
5 unchanged sentences
As of April 1, 2026 , 117 partners led the firm, with an average of over 20 years of investment or industry experience.
−Removed: As of March 31, 2025, nearly two-thirds of our employees have equity interests in us in the form of direct equity interests and/or restricted stock units under our 2020 Long-Term Incentive Plan (“LTIP”), and more than 200 employees are eligible to participate in our carried interest allocations in one or more of the asset classes.
+Added: As of March 31, 2026, over two-thirds of our employees have equity interests in us in the form of direct equity interests and/or restricted stock units under our 2020 Long-Term Incentive Plan (“LTIP”), and more than 200 employees are eligible to participate in our carried interest allocations in one or more of the asset classes.
Strategic Priorities
21 unchanged sentences
Monetize Our Data and Analytics Capabilities
−Removed: Our proprietary database, SPI Research, provides access to valuable data that forms the cornerstone of our investing process.
−Removed: We license SPI Research to clients in the form of a traditional licensed offering as well as an “advisory-like” service where we offer the SPI Research license and limited advisory-type support from our team.
+Added: In addition to enabling StepStone's asset management and advisory solutions, our proprietary data and technology platform, SPI by StepStone, includes a suite of applications that are made available directly to our clients.
+Added: We typically deliver these capabilities as part of broader client mandates, and we also monetize certain tools and datasets through standalone licenses and data distribution partnerships.
+Added: SPI Research is our private markets intelligence database, containing the qualitative and quantitative insights from StepStone's approximately 420 investment professionals.
+Added: We primarily provide SPI Research in connection with asset management and full-service advisory mandates, and we also license it on a standalone basis, including an “advisory-like” arrangement that combines platform access with limited advisory support.
This has allowed us to support the private markets activities of clients that are too small to participate in our full-service advisory offerings.
−Removed: SPI Reporting and SPI Research both allow users to leverage our research data, further enhancing our client experience and services.
−Removed: We also strategically use SPI Research and SPI Reporting as a competitive product bundle, for example, by providing both offerings to clients to secure more comprehensive mandates.
+Added: SPI Reporting is used by clients post-investment to monitor the performance and exposures of their private market portfolios.
+Added: SPI Reporting is typically bundled with SPAR, which is a managed service that gathers, validates, and maintains private markets fund reporting data and related portfolio information that can be resource intensive for clients to administer internally.
+Added: See “Portfolio Analytics and Reporting—SPI Reporting Platform” below for more information.
+Added: SPI Pacing is a portfolio cash flow, investment allocation and liquidity forecasting tool that is used by investors to create customized commitment plans to assist in reaching allocations targets and manage liquidity in private market portfolios.
+Added: SPI Benchmarking includes a collection of data products and analytical tools that leverage StepStone's vast proprietary data sourced across its business.
+Added: These individual data products are available to all market participants, providing better intelligence and transparency across different segments of private markets.
+Added: StepStone has also established strategic partnerships with industry leaders in different segments of financial services that have unique data assets and distribution channels.
+Added: Together with StepStone’s capabilities, these partners help deliver innovative data solutions tailored to private markets stakeholders.
+Added: Representative data distributions partnerships include agreements with Kroll, FTSE Russell, and PitchBook.
Pursue Accretive Transactions to Complement Our Platform
41 unchanged sentences
This further expands our investment opportunities and differentiates us from other co-investors, thereby leading to future opportunities with fund managers.
−Removed: Our co-investment program benefits from the access to fund managers we have through our scale and the approximately 5,600 meetings and calls that we conduct with fund managers on an annual basis.
+Added: Our co-investment program benefits from the access to fund managers we have through our scale and the over 5,700 meetings and calls that we conduct with fund managers on an annual basis.
In each of these meetings and calls, we follow a protocol of inquiring about co-investments and monitoring compliance with the protocol through an automated tracking system.
Portfolio Analytics and Reporting
−Removed: We provide our clients with tailored reporting packages, including customized performance benchmarks as well as compliance, administration and tax capabilities.
−Removed: The team of professionals dedicated to SPAR is organized by sector and geography to promote deep coverage of all private markets, facilitating detailed investment review and analysis services by private markets specialists.
−Removed: Once an investment has been made, our SPAR team provides active, ongoing analytical review for portfolio risk management for our clients.
−Removed: As part of our ongoing manager and portfolio performance analyses, our portfolio analytics and reporting practice completes reviews for our clients including:
−Removed: • portfolio benchmarking for relative performance;
−Removed: • diversification analysis to identify concentration risks or portfolio allocation opportunities;
−Removed: • fund manager performance to understand where additional capital should be directed;
−Removed: • valuation analysis to determine which fund managers are appropriately reflecting risk in their reporting.
−Removed: Fund managers’ information is entered into SPI Reporting, our proprietary, web-based application and database for private market portfolio analytics and reporting.
−Removed: Data are reconciled daily to help ensure data integrity and that pertinent details are entered correctly.
−Removed: In order to be included in SPI Reporting, a fund manager must send us sufficient materials, including specific data fields required by us.
−Removed: Performance data monitored by SPI Reporting is available back to 1971.
−Removed: SPI Reporting supports investment monitoring and portfolio management and enhances transparency by providing users with a fast and intuitive user interface and web-based access to portfolio data.
−Removed: SPI Reporting users can access all of the data tracked by SPAR, including daily cash flow activity, quarterly valuations, and underlying asset-level detail, and have fully integrated access to our SPI by StepStone platform.
−Removed: SPI Reporting users can analyze investment-level and underlying asset-level performance by custom investment attributes, apply data filters, run grouped or granular reports while also having the ability to easily export these analyses.
−Removed: Users also have the ability to edit, run and export various portfolio analytics, including analyzing various return and preference metrics commonly used in the investment industry, such as return J-Curve, cash flow activity over time, multi-period internal rates of return and time-weighted rate of return.
+Added: StepStone Portfolio Analytics & Reporting
+Added: StepStone's Portfolio Analytics & Reporting service, known as SPAR, is an investment monitoring and reporting solution that provides institutional investors with end-to-end private markets data management, portfolio monitoring, and reporting capabilities.
+Added: Designed to support informed decision making, SPAR functions as a fully integrated operational partner, combining an experienced global team, rigorous data management processes, and proprietary analytical tools to give clients continuous transparency into their private markets portfolios.
+Added: Data Monitoring
+Added: At the core of SPAR is a disciplined data monitoring process that captures, validates, and maintains investment data across private markets asset classes.
+Added: SPAR collects documents from general partners through a centralized intake portal, logs and organizes them using standardized conventions, then processes the data.
+Added: The data are reconciled against general partner, client, and/or custodian records to ensure accuracy and integrity.
+Added: SPI Reporting Platform
+Added: Processed data flows directly into SPI Reporting, a web-based monitoring and reporting platform accessible on a continuous basis.
+Added: The platform tracks over 100 data points per investment, including daily cash flow activity, quarterly valuations, and underlying asset-level detail, and provides interactive dashboards covering capital activity, performance, public and private benchmarking, and portfolio exposures.
+Added: Users can analyze performance at the investment and underlying asset level by custom attributes, apply data filters, and run grouped or granular reports with export capability.
+Added: The platform also supports portfolio analytics including return J-curves, cash flow activity over time, multi-period internal rates of return, and time-weighted rates of return.
+Added: SPI Reporting is integrated with SPI Pacing and SPI Research, allowing clients to manage allocations and access StepStone's broader research platform.
+Added: The system is developed and maintained by StepStone's in-house DATS team of over 30 engineers.
+Added: Client Service
+Added: SPAR's dedicated client service team serves as the primary point of contact for each account, managing onboarding, training, and ongoing support.
+Added: The team coordinates client and portfolio manager investment monitoring support across StepStone, delivers tailored periodic reporting packages, and handles ad hoc data requests – all subject to quality review prior to delivery.
+Added: Global coverage spans major regions, ensuring clients receive consistent, timely service regardless of geography.
Investment Risk Management
−Removed: We have an investment risk management function overseen by our Head of Research and Portfolio Management and our Head of Risk.
−Removed: Additionally, taking into account the nature, scale and complexity of our business, we have a Portfolio and Risk Management Committee for each of our asset classes and additional policies and procedures to give effect to local regulations in jurisdictions around the world.
+Added: Given the nature and scale of the business, Investment Committees (“ICs”) and Portfolio and Risk Management Committees (“PRMCs”) have been established for each asset class.
+Added: Additionally, a Global Allocation Committee (“GAC”) oversees multi-asset class matters, particularly capital markets assumptions, providing a holistic view of risk and portfolio exposure across asset classes and alignment with overall investment objectives and risk management strategies.
+Added: Each of the PRMCs and ICs provide oversight of portfolio and investment risk, respectively.
Our risk management process focuses on risk identification, measurement, treatment/mitigation, monitoring and management/reporting, with particular risk assessments tailored by asset class and individual client.
6 unchanged sentences
• Adopted a Responsible Investment policy in 2014, which is reviewed annually;
−Removed: • Became a member of the Sustainability Accounting Standards Board (“SASB”) and enhanced our governance framework by creating asset class RI workgroups in 2019;
+Added: • Became a member of the Sustainability Accounting Standards Board (“SASB”) and its successor the International Sustainability Standards Board;
+Added: • Enhanced our governance framework by creating asset class RI workgroups and a dedicated corporate RI Workgroup in 2019;
• Became a member of the GRESB and a founding signatory to the Institutional Limited Partners Association (“ILPA”) Diversity in Action initiative in 2020;
3 unchanged sentences
Accepted as a signatory to the UK Stewardship Code in 2023 and again in 2024;
+Added: • Were elected as a representative to the ESG Data Convergence Initiative Steering Committee in 2024 and continue to serve in this role;
+Added: • Continued to evolve our investment practices by deepening our focus on financially material issues, including physical climate risk, AI and technology governance, and supply chain considerations.
Responsible Investment in the Investment Process
12 unchanged sentences
Post investment, we monitor the co-investment’s performance focusing on material financial and RI factors.
−Removed: The majority of this monitoring is conducted through regular engagement with the fund manager supplemented by Limited Partner Advisory Committees of which we are a member.
+Added: The majority of this monitoring is conducted through an annual questionnaire and regular engagement with the fund manager supplemented by Limited Partner Advisory Committees of which we are a member.
In cases where we hold a board or observer seat at the fund, we seek to be active in advocating for material issues as standard agenda items.
16 unchanged sentences
Modern Slavery
−Removed: We have processes in place to address the applicable regulatory obligations in certain jurisdictions where we operate related to modern slavery, which encompass forced labor, human trafficking, and child labor.
+Added: We have processes in place to address the applicable regulatory obligations in certain jurisdictions where we operate related to modern slavery, which includes forced or compulsory labor, human trafficking, child labor, restrictions on freedom of association, unsafe or unhealthy working conditions, and the use of physical punishment, coercion, or abusive disciplinary practices.
Within our vendor due diligence process, we query and evaluate for this topic seeking to identify any substantive supply chain risks.
4 unchanged sentences
We believe the stability of our client base, reflecting in part the longer tenor of our SMAs and focused commingled funds, reflects the strength of the long-term client relationships we have developed.
−Removed: We have also had a high level of success in retaining our advisory clients with an approximately 95% retention rate since inception.
−Removed: At the same time, we believe we have been successful in expanding relationships with our clients, often expanding from advisory relationships to discretionary asset management relationships.
+Added: We believe we have been successful in expanding relationships with our clients, often expanding from advisory relationships to discretionary asset management relationships.
Approximately 34% of our clients engage us for both asset management and advisory services.
54 unchanged sentences
(iv) consulting on investment pacing, policies, strategic plans, and asset allocation to investment boards and committees;
−Removed: and (v) licensed access to our proprietary data and technology platforms, including SPI Research and our other proprietary tools.
−Removed: Mandates for SPAR services typically include licensed access to SPI Reporting, our proprietary web-based performance monitoring and reporting solution.
−Removed: SPI Reporting allows our clients to customize performance measurement and benchmarking according to their unique specifications.
+Added: and (v) licensed access to our proprietary data and technology platform, SPI by StepStone.
+Added: Advisory mandates generally include StepStone’s SPAR service, which is a managed service for monitoring and reporting on private market investments.
+Added: Our SPAR service typically includes licensed access to SPI Reporting, our proprietary portfolio reporting application that provides investors with customizable performance, exposure, and benchmarking analysis.
Our advisory relationships comprised $652 billion of our AUA and $16 billion of our AUM as of March 31, 2026.
35 unchanged sentences
Failure to comply with the requirements of the Investment Advisers Act or the rules and regulations promulgated by the SEC thereunder could have a material adverse effect on our business.
−Removed: In May 2024, the SEC adopted amendments to Regulation S-P (the privacy regulations applicable to financial institutions, including investment advisers) that will expand the scope of the regulation and mandate notification to clients and customers in the event of privacy breaches.
+Added: In May 2024, the SEC adopted amendments to Regulation S-P (the privacy regulations applicable to financial institutions, including investment advisers) that expanded the scope of the regulation and mandate notification to clients and customers in the event of certain privacy breaches.
+Added: We were required to comply with these amendments by December 2025.
+Added: The amendments include new and operationally challenging notification and timing requirements, as well as expanded obligations relating to oversight of service providers.
The SEC has also adopted disclosure rules related to cybersecurity applicable to public companies.
−Removed: In addition, the SEC and FinCEN have recently jointly adopted a new rule that will require investment advisers to adopt formal anti-money laundering and customer identification programs by the end of 2025.
−Removed: Bringing our firm into compliance with these new rules (and any others adopted by the SEC), could result in a significant increase in the compliance risks and regulatory burden of operating our business.
+Added: In addition, in 2024, FinCEN and the SEC adopted rules that would require investment advisers to establish formal anti-money laundering and customer identification programs and to file suspicious activity reports.
+Added: On December 31, 2025, FinCEN and the SEC issued a statement delaying the implementation of the rule from January 1, 2026 to January 1, 2028, and are evaluating potential further changes to the rule.
Our SMAs and the majority of our focused commingled funds are not registered under the Investment Company Act because we only form SMAs for, and offer interests in our focused commingled funds to, persons who we reasonably believe to be “qualified purchasers” as defined in the Investment Company Act.
17 unchanged sentences
If for any reason these rules were to become inapplicable, we could become subject to regulatory action or third-party claims that could have a material adverse effect on our business.
+Added: On March 30, 2026, the U.S.
+Added: Department of Labor (“DOL”) introduced a proposed rule which, though applicable to the selection of any designated investment alternatives, is expected to facilitate an ability for individuals to allocate a portion of their 401(k) investments in alternative assets, such as private equity and private credit, as well as real estate.
+Added: Central to the proposal is a process-based “safe harbor,” which grants plan fiduciaries the presumption of fulfilling their duty of prudence under ERISA, provided they “objectively, thoroughly, and analytically” evaluate six specific factors outlined in the rule:
+Added: performance, fees, liquidity, valuation, performance benchmarks, and complexity.
+Added: By adhering to this framework when making investment decisions, fiduciaries are presumed to have met ERISA’s prudence standard, thereby helping to mitigate the legal risks often associated with offering alternative investments.
+Added: The proposed rule, if adopted, is expected to result in greater interest by employers in adding plan investment options with private markets exposure.
+Added: AI and Information Technology-Related Regulation
+Added: Governmental authorities in the United States and foreign jurisdictions have increased their focus on the use of artificial intelligence (“AI”), proposing, adopting or considering laws and regulations that may require governance, transparency, risk management and other controls in connection with the development or use of AI systems.
+Added: In the United States, the SEC has established a task force and is evaluating the need for rules and regulations.
+Added: If enacted, such rules could add to the compliance risks and burdens of using this technology.
+Added: Regulation (EU) 2024/1689, the European Union's Artificial Intelligence Act ("EU AI Act"), entered into force on August 1, 2024 and established a legal framework for the development and use of artificial intelligence systems in the European Union.
+Added: Compliance with such requirements, and the potential for enhanced liability or regulatory enforcement related to AI, could increase our costs and complexity and adversely affect our business.
Foreign Regulation
We provide investment advisory and other services and raise funds in a number of countries and jurisdictions outside the United States.
−Removed: In a number of these countries and jurisdictions, which include the UK, European Union (“EU”), the European Economic Area (“EEA”) and certain of the individual member states of each of the EU and EEA (including Ireland and Luxembourg), Switzerland, Japan, Korea, Singapore, Canada and Brazil, our operations, and in some cases our personnel, are subject to regulatory oversight and affirmative requirements.
+Added: In a number of these countries and jurisdictions, which include the UK, European Union (“EU”), the European Economic Area (“EEA”) and certain of the individual member states of each of the EU and EEA (including Ireland and Luxembourg), Switzerland, Japan, Korea, Singapore, Canada, Saudi Arabia, Mexico and Chile, our operations, and in some cases our personnel, are subject to regulatory oversight and affirmative requirements.
These requirements variously relate to registration, licenses for our personnel, periodic inspections, the provision and filing of periodic reports and obtaining certifications and other approvals.
In the EU, we are subject to the EU Alternative Investment Fund Managers Directive (“AIFMD”), the EU Alternative Investment Fund Managers Directive II (“AIFMD II”) and the Undertakings for Collective Investment in Transferable Securities Directive (“UCITS”) under which we are subject to regulatory requirements regarding, among other things, registration for marketing activities, the structure of remuneration for certain of our personnel and reporting obligations.
−Removed: AIFMD II entered into force in the EU on April 15, 2024 and member states have two years to implement the rules into national law.
+Added: AIFMD II entered into force in the EU on April 15, 2024 and member states have two years to implement the rules into national law, which we expect to occur in 2026.
+Added: As implemented, AIFMD II may impose additional requirements or restrictions on certain alternative investment funds (including with respect to liquidity management and, for certain strategies, loan origination activities) and could increase the complexity and cost of conducting our business in the EU and EEA.
Our EU-based subsidiary, StepStone Group Europe Alternative Investments Limited (“SGEAIL”), engages in regulated activities within the EU.
−Removed: SGEAIL is authorized by the Central Bank of Ireland pursuant to AIFMD and UCITS and authorized to provide certain MiFID II services, and is preparing for compliance with AIFMD II.
+Added: SGEAIL is authorized by the Central Bank of Ireland pursuant to AIFMD and UCITS and authorized to provide MiFID II top up services.
Switzerland and individual member states of the EU have imposed additional requirements that may include internal arrangements with respect to risk management, liquidity risks, asset valuations, and the establishment and security of depository and custodial requirements.
7 unchanged sentences
EU member states have 36 months to transpose the legislation into national law.
−Removed: Regulation (EU) 2022/2554 on digital operational resilience for the financial sector (“DORA”) establishes a harmonized and comprehensive digital operational resilience framework across the whole EU financial sector by requiring a wide range of financial entities, including asset managers and investment firms, to manage their information and communication technology (“ICT”) risks in a robust and effective way through internal governance, control and risk frameworks.
+Added: Regulation (EU) 2022/2554 on digital operational resilience for the financial sector (“DORA”) establishes a harmonized and comprehensive digital operational resilience framework across the EU financial sector by requiring a wide range of financial entities, including asset managers and investment firms, to manage their information and communication technology (“ICT”) risks in a robust and effective way through internal governance, control and risk frameworks.
DORA also requires financial institutions to report major ICT-related incidents to regulatory authorities and undertake digital operational resilience testing.
−Removed: DORA came into force from January 17, 2025.
−Removed: There have also been significant legislative developments affecting the private equity industry in Europe and there continues to be discussion regarding enhancing governmental scrutiny and/or increasing regulation of the private equity industry.
+Added: DORA came into force on January 17, 2025.
+Added: Regulation (EU) 2024/1689 sets forth harmonized rules on artificial intelligence (the “EU AI Act”) and establishes a harmonized, risk-based regulatory framework across the European Union for the development, placing on the market, and use of artificial intelligence systems.
+Added: The EU AI Act applies to providers, deployers, importers, and distributors of AI systems, including entities established outside the EU where AI outputs are used within the Union (extraterritorial effect).
+Added: It introduces a tiered system of obligations based on risk;
+Added: prohibiting certain AI practices, while also imposing stringent requirements on high-risk AI systems, including those used in employment and recruitment contexts, such as risk management, data governance, transparency, and human oversight.
+Added: The EU AI Act aims to ensure that AI systems are safe, transparent, and respect fundamental rights, while supporting innovation and the effective functioning of the EU single market.
+Added: The Regulation entered into force on August 1, 2024, with phased implementation, including the application of prohibited practices from February 2025 and full application from August 1, 2026.
+Added: In parallel, the European Commission is progressing the Digital Omnibus IV package, which is expected to streamline and align overlapping obligations across EU digital legislation, including the AI Act, to enhance regulatory coherence and supervisory coordination.
+Added: The Digital Omnibus IV package purports to extend the deadline for implementation from August 2026 to December 2027, however this remains in trilogue negotiations within the EU.
+Added: For more information regarding regulatory risks, see Part I, Item 1A “Risk Factors” of this Form 10-K, including “Risk Factors—Risks Related to Our Industry—We operate in an industry subject to numerous regulations and any failure to comply with government regulations to which we are subject could adversely affect us” and “—Evolving laws and government regulations could adversely affect us.”
Human Capital
Our People and Culture
−Removed: Our core values and beliefs include “People Matter” and “Empowered Team.” We recognize our people are our biggest asset and their enthusiasm, hard work and dedication make everything that we do possible.
+Added: Our core beliefs include “People Matter” and “Empowered Team.” We recognize our people are our biggest asset and their enthusiasm, hard work and dedication make everything that we do possible.
We emphasize integrity, transparency, collaboration, entrepreneurialism, and respect for all, driving how we interact with one another, our clients and investors, sponsors, vendors and service providers, and the community at large.
1 unchanged sentence
We measure employee satisfaction and engagement through a variety of surveys.
−Removed: As of March 31, 2025, we had approximately 1,130 employees globally, including over 375 investment professionals and approximately 750 employees across our operating team and implementation teams dedicated to sourcing, executing, analyzing and monitoring private markets opportunities.
+Added: As of March 31, 2026, we had over 1,310 employees globally, including approximately 420 investment professionals and approximately 890 employees across our operating team and implementation teams dedicated to sourcing, executing, analyzing and monitoring private markets opportunities.
We consider our relationship with our employees to be good and have not experienced interruptions of operations due to labor disagreements.
15 unchanged sentences
We offer our team members the benefit of a collegial, intellectually challenging environment where they are empowered to exercise their creativity.
−Removed: As an example, our sponsorship program seeks to identify high-potential employees in mid-level roles, and partners them with one of the firm’s partners, who serves as a sponsor, as well as an executive coach, and is intended to support participants in advancing their professional development and leadership skills.
+Added: We also leverage AI to support and enhance our human capital capabilities globally and to enable more efficient, scalable human capital operations.
+Added: We believe that further AI deployment will drive additional efficiencies which will empower employees to focus on highly strategic value-added contributions.
+Added: We have a number of programs and resources to support and offer development to our employees.
+Added: Our sponsorship program seeks to identify high-potential employees in mid-level roles, and partners them with one of the firm’s partners, who serves as a sponsor, as well as an executive coach, and is intended to support participants in advancing their professional development and leadership skills.
Our mentor program provides interested employees with structured access to one of their more senior colleagues who provide guidance and career advice.
10 unchanged sentences
Our LTIP provides us the ability to offer a variety of equity-based awards, and our employee stock purchase plan allows us to offer equity for purchase at an attractive discount to the market price through payroll deductions, in each case, to further incentivize our employees.
+Added: We also maintain a plan under which certain of our employees are granted equity in certain of our evergreen funds.
In addition, we award annually a portion of carried interest allocations earned by us to certain employees.
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Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.