ESMA has released its latest update to the running  UCITS Q&As, which contains new Q&As confirming that the remuneration disclosure requirements also apply to staff of the delegate of an UCITS management company to whom investment management functions have been delegated. Two options are provided: either the delegate is subject to equivalent disclosures requirements, and in this case the management company uses the information disclosed to fulfil its own obligations; or “appropriate contractual arrangements” are to be put in place with the delegate to allow the management company to receive the information to be disclosed. The disclosure should be done on a prorated basis for the part of the UCITS’ assets which are managed by the identified staff with in the delegate.

This is in line with the requirements under AIFMD and the similar October 2017 update of the AIFMD Q&As.

If you have any questions, do not hesitate to contact Marie-Adélaïde de Nicolay