Foreword
The AIFMD Review Directive (Directive (EU) 2024/927) introduced new requirements for AIFMs and AIFs under AIFMD and for UCITS and UCITS management companies under the UCITS Directive.
Although the Directive directs Member States to apply the transposed requirements of the AIFMD Review Directive from 16 April 2026, this may not answer the question of how long managers have to come into compliance with respect to existing funds and clients. This will depend on the terms of the individual Member State transpositions, as well as any forbearance by, or direct engagement by managers with, NCAs. Given this uncertainty, the most conservative approach is to assume that compliance will be required by 16 April 2026 until more specific guidance to the contrary is available.
Many of the new requirements under the AIFMD Review Directive create dependencies causing some aspects of the new requirements to be in place before other steps can be taken, with all steps having to be taken in order ending on or before the compliance date. Lead times should be taken into account. It would be prudent for managers (especially authorised management companies) to begin their implementation projects as soon as possible. Scoping the implementation project would be a sensible first step.
AIMA, in conjunction with the ACC, has published a set of implementation guides designed to help AIMA members in this regard. Each of these implementation guides can be accessed by members via the links acessible below. The launch webinar recordings will also be accessible from this page following those events.
Questions regarding the AIFMD Review Directive and the materials on this page should be directed to Jennifer Wood ([email protected]).
AIFMD 2
Members with a log-in should log-in here to be provided with a download link to the Report
Members with a log-in should log-in here to be provided with a download link to the Guide.
For further information please contact Jennifer Wood, Managing Director, Global Head of Asset Management Regulation & Sound Practices.
UCITS Directive
Members with a log-in should log-in here to be provided with a download link to AIFMD Review Focusing on UCITS.
For further information please contact Jennifer Wood, Managing Director, Global Head of Asset Management Regulation & Sound Practices.
Other AIFMD Review Resources
Implementation Guide Launch Webinars
To sign up for upcoming webinars marking the launch of each of the implementation guides discussed above, see:
| 19 November, 4 p.m. London time | AIFMD for AIFMs and AIFs (presented by Maples) | Sign up here |
| 21 November, 10 a.m. London time | Loan Origination and Loan-Originating AIFs (presented by Travers Smith) | Sign up here |
| Date and time TBC | AIFMD Review: Focusing on UCITS (presented by Simmons & Simmons) | Watch this space |
Members will also be able to access the recordings of the webinar sessions launching each of the three implementation guides from this spot once those recordings are available.
Ongoing Discussion Forum
Manager members are invited to join AIMA's AIFMD Review Directive Implementation Discussion Forum. This is a manager member only peer-to-peer discussion group focusing on implementation related challenges arising from the changes to AIFMD and the UCITS Directive. Calls are approximately every two to three weeks. Call agendas are set based on questions received from members in advance. Interested manager members should contact Jennifer Wood ([email protected]) to sign up.