AIFMD II compliance for EU private funds
Directive (EU) 2024/927, commonly referred to as AIFMD II, amends the original Alternative Investment Fund Managers Directive (Directive 2011/61/EU) and the UCITS Directive. It entered into force on 15 April 2024, and Member States must transpose it into national law by 16 April 2026. It introduces new rules for loan-originating funds, mandatory liquidity management tools, expanded delegation transparency and enhanced supervisory reporting.
Key changes AIFMs need to prepare for
- a harmonised regime for loan-originating AIFs, including leverage limits and risk-retention requirements
- mandatory selection of liquidity management tools (LMTs) for open-ended AIFs from a list defined in Annex V
- expanded delegation disclosures to national competent authorities and ESMA
- enhanced Annex IV reporting (asset composition, leverage, liquidity, exposures) with more granular data fields
- new depositary provisions and revised marketing rules
Where Reuben AI helps
1. Loan-originating fund operations
Origination, underwriting, portfolio construction and risk-retention tracking are handled inside the same platform, with leverage and concentration limits configured at the vehicle level and enforced on every transaction.
2. Liquidity management tools
LMT selection (redemption gates, notice periods, side pockets, swing pricing, redemption fees) is configured at the vehicle level and applied automatically on every subscription and redemption cycle, with the audit trail regulators expect.
3. Delegation transparency
Delegates, sub-delegates, functions performed and human and technical resources are tracked in a single register with change history so delegation notifications to the NCA and ESMA can be produced from live data.
4. Annex IV supervisory reporting
Portfolio composition, leverage, liquidity profile and counterparty exposures are maintained as live data. Annex IV report packs draw from the same reconciled source, so filings match the underlying position records.
5. LP disclosure alignment
Pre-contractual disclosures required by AIFMD II (leverage, LMTs available, delegation arrangements) are generated from the same source used for LP reporting, so what LPs see and what the regulator sees are consistent.
Primary sources
- Directive (EU) 2024/927 (AIFMD II), EUR-Lex
- Directive 2011/61/EU (original AIFMD), EUR-Lex
- ESMA, AIFMD policy page
This page describes how Reuben AI supports compliance workflows. It is not legal advice. AIFMs should confirm all interpretations with their own compliance counsel and, where relevant, their national competent authority.