AIFMD II and UCITS changes: reporting standards due 2027

Directive (EU) 2024/927 amends the Alternative Investment Fund Managers Directive (AIFMD), which covers funds such as hedge, private equity and property funds, and the UCITS Directive (undertakings for collective investment in transferable securities), which covers the standard EU retail fund. It addresses managers handing core tasks to other firms, funds facing large redemption requests, and funds that lend directly to companies (Directive (EU) 2024/927 (external site)).

Most of the new rules apply from 16 April 2026. What is still to come is supervisory reporting, the data managers send to their national supervisor, rebuilt through standards drafted by the European Securities and Markets Authority (ESMA) (Directive (EU) 2024/927 (external site)).

The manager of an open-ended fund, one that investors can leave on request, selects at least two liquidity management tools from a list in the directive, for example redemption fees, swing pricing or redemption in kind (Directive (EU) 2024/927 (external site)).

A delegated regulation sets how each tool works. Under swing pricing, the price is moved by a swing factor that passes trading costs to the investors who enter or leave, and the published NAV (net asset value) is the value after that factor (Delegated Regulation (EU) 2026/465 (external site)).

A fund that originates loans keeps 5 percent of the notional value of each loan it sells on. Its leverage, exposure divided by net asset value, is capped at 175 percent if open-ended and 300 percent if closed-ended (Directive (EU) 2024/927 (external site)). As an example, a closed-ended loan fund with EUR 100 million of net assets could carry up to EUR 300 million of exposure.

Managers report regularly on delegation arrangements, the portfolio or risk management tasks given to other firms, including where each delegate is established (Directive (EU) 2024/927 (external site)). A supervisor may allow an alternative fund to appoint a depositary, the firm that holds the fund's assets and checks its rules, in another Member State after a case-by-case assessment (Directive (EU) 2024/927 (external site)).

The rules apply to managers of alternative funds and UCITS management companies, and reach fund administrators and depositaries through the tasks they perform for funds (Directive (EU) 2024/927 (external site)).

• Portfolio Analyst: leverage caps and retention rules enter the construction of loan-originating funds.
• Investment Risk Analyst: calibrates and monitors the liquidity management tools each fund has selected.
• Fund Accountant: applies swing factors and other anti-dilution tools when the net asset value is struck.
• Depositary Oversight Analyst: oversight covers the new fund rules and cross-border depositary appointments.
• Investment Operations Analyst: keeps the data on delegates that the reports require.
• Fund Reporting Analyst: prepares supervisory reports in the new content and format once the standards apply.

The directive was published in the Official Journal on 26 March 2024 and entered into force on 15 April 2024 (ESMA report on integrated reporting (external site)). Member States applied it from 16 April 2026, except the reporting provisions, which apply from 16 April 2027 (Directive (EU) 2024/927 (external site)).

ESMA submits draft RTS (regulatory technical standards) on the content and format of reporting by 16 April 2027. Its May 2026 report places them in the first phase of integrated funds reporting (ESMA report on integrated reporting (external site)).

By 16 April 2029 ESMA reports on delegation practices, and the Commission then opens a review of the directive (Directive (EU) 2024/927 (external site)). All these dates are set in law.

The AIFMD dates from 2011 and the UCITS Directive from 2009. The 2021 Commission proposal found that ESMA needed more information on delegation, in particular where portfolio or risk management is delegated outside the EU (COM(2021) 721 (external site)).

A further Commission proposal of 4 December 2025 would amend both directives again, including on intra-group delegation and depositaries. It is in the ordinary legislative procedure (COM(2025) 942 (external site)).