Navigating AIFMD II
Updated: June 2025The Alternative Investment Fund Managers Directive (AIFMD) II represents a significant evolution in the regulatory framework for alternative investment funds in Europe. Building upon the original AIFMD implemented in 2011, this updated directive introduces several key changes that fund managers need to understand and prepare for.
Key Changes in AIFMD II
- Enhanced Reporting Requirements: More detailed and frequent reporting obligations, particularly regarding leverage and liquidity management.
- Loan Origination Rules: New restrictions and requirements for funds engaged in loan origination activities.
- Depositary Liability: Clarification and extension of depositary liability provisions.
- Marketing Requirements: Stricter rules on marketing practices and investor disclosures.
Implementation Timeline
The directive entered into force in January 2023, with EU member states required to transpose it into national law by August 2023. Full compliance will be required by early 2024, giving firms limited time to adapt their operations.
Action Points for Fund Managers
- Conduct a comprehensive gap analysis of current operations against new requirements
- Review and update compliance policies and procedures
- Enhance reporting systems to meet new data requirements
- Train staff on new obligations and operational changes
- Engage with regulators and depositaries early in the process
The CSC team is closely monitoring the implementation of AIFMD II across different jurisdictions and can provide tailored advice to ensure your firm remains compliant while maintaining operational efficiency.