AIFMD II: Six Months to Go — Time to Move from Monitoring to Execution

While the new framework primarily targets EU managers, important elements will also affect non-EU AIFMs that market into the EU.

What Matters

• Liquidity Management Tools (LMTs)
  
  Each open-ended AIF must select and be able to activate at least two LMTs.
  The Regulatory Technical Standards (RTS) have been finalised by ESMA, but are still awaiting adoption by the European Commission.
   
• Open-Ended Loan-Originating AIFs
  
  ESMA’s RTS covering liquidity, buffers, stress tests, and redemptions - originally expected in H2 2025 - are delayed.
  The Commission confirmed that non-essential Level 2 acts will not be adopted before 1st October 2027. In the meantime, Member States may introduce interim rules.
   
• National Implementation
  
  Because AIFMD II is a Directive, it requires national transposition. This means national laws and supervisory guidance must be updated by 16th April 2026.
  However, full implementation remains outstanding in key EU Member States.
   
• Annex IV Reporting
  
  Enhanced Annex IV reporting goes live on 16th April 2026 with AIFMD II.
  The new reporting requirements apply immediately. But the updated RTS/ITS templates (covering delegation and liquidity data) are only due by 16th April 2027.

What to Watch in the Coming Months
 

• The European Commission’s adoption of the RTS on liquidity management tools
• ESMA’s RTS on open-ended loan-originating AIFs and potential national rules
• National transposition of AIFMD 2.0 by 16th April 2026

Fenion's Support

At Fenion, we’re ready to support AIFMs with AIFMD II / Annex IV reporting obligations through:

• Highly automated processes to reduce manual effort
• 1,000+ validations to ensure compliance with ESMA and NCA standards
• AIFM and AIF reports for National Competent Authorities