With just one month until the local transposition deadline on 16 April 2026, it is worth reminding how AIFMD II will impact the Annex IV reporting by adding new requirements and refining existing ones.
ESMA’s technical standards are expected to be finalised before the end of the year, paving the way for the first reporting under the revised framework in Q1 2027.
At the same time, proposed changes to the UCITS Directive will introduce a new supervisory reporting framework that will closely mirror the structure of AIFMD Annex IV, helping to bring greater alignment across both regimes.
Timeline
15 April 2024
Entry into force of AIFMD II on 15 April 2024 marked the start of a 24‑month transition period during which EU Member States are expected to implement the revised rules into their national regulatory frameworks.
16 April 2026
Deadline for EU Member States to transpose AIFMD II into national law, ensuring the new requirements are integrated into local legislation (Luxembourg and others must be aligned by this date).
16 April 2027
Start date for the new AIFMD II supervisory reporting obligations. ESMA is expected to publish the final Regulatory Technical Standards (RTS) and Implementing Technical Standards (ITS) that will specify the detailed reporting during the second half of 2026 to ensure readiness for the first reporting obligations under the new Directive in Q1 2027.
Detailed summary of expected changes
Expanded dataset
The current focus on “principal markets” and “main exposures” will be replaced by a requirement to report all relevant instruments, exposures and markets. This creates a far more comprehensive, but also more complex, reporting dataset than under the existing Annex IV template.
The updated reporting framework will use identifiers to link reported data to public or supervisory sources, enhancing consistency and comparability. This may present challenges depending on the asset type, particularly where standardised identifiers are lacking.
Enhanced governance transparency
Managers will need to provide more granular information regarding their internal governance and delegation, including:
Delegate / sub‑delegate mapping: names, domiciles and regulatory status, including structured information allowing authorities to understand the delegation chain.
Delegation scope: what is delegated (portfolio and/or risk management), potentially including how much activity/assets are in practice covered by delegated arrangements.
Resourcing and substance indicators: data points such as resources involved in day‑to‑day portfolio/risk management internally, and resources dedicated to monitoring delegation.
Oversight controls: evidence that oversight is active—e.g., dates and outcomes of due diligences, issues raised, remediation plans and timelines.
Cross-border distribution
Disclosure will have to include each EU Member State where a fund is marketed, increasing supervisors’ visibility over cross‑border distribution.
UCITS: A new supervisory reporting obligation introduced via the UCITS Directive update (UCITS VI)
AIFMD II does not only change AIFMD Annex IV reporting: it also amends the UCITS Directive (UCITS VI) to introduce a new formal supervisory reporting obligation for management companies in respect of each UCITS they manage, broadly mirroring the logic of the AIFMD supervisory reporting regime (i.e., regular reporting to the home National Competent Authority ("NCA") on trading activity, exposures/assets, liquidity management arrangements, risk profile, stress testing, delegation and marketing footprint).
The Directive framework foresees that these UCITS reporting measures will apply from April 2027, supported by ESMA RTS/ITS specifying the practical reporting standards and submission format.
Should you have any questions, or if you would like to discuss what these changes mean for your reporting model, data readiness or implementation roadmap, please do not hesitate to contact our experts to schedule a discussion on this topic.
