On 26 March 2024, a Directive amending AIFMD and the UCITS Directive was published in the Official Journal of the EU (the “Directive”). The Directive entered into force on 15 April 2024. Member States now have until 16 April 2026 to transpose the Directive into national law. The measures introduced by the Directive will then be subject to a general review set to commence by 16 April 2029.

Because the Directive contains amendments to multiple parts of AIFMD, as well as amendments to the UCITS Directive, all alternative investment fund managers (“AIFMs”), UCITS and UCITS management companies (“UCITS Managers”) will be affected to a greater or lesser degree. The focus of managers and promoters will be to digest, operationalise and implement the new rules and requirements now that they have been finalised, in readiness for the new requirements taking effect.

While this summary aims to give an overview of the changes introduced by the Directive, it should be borne in mind that it is based on the “level 1” text of the Directive. It will of course be important to monitor both how individual Member States transpose it, and the content and effect of the Implementing Measures which underpin several of the key aspects of the Directive.