AIFMD 2 updates two existing EU rulebooks, the Alternative Investment Fund Managers Directive (AIFMD) itself, and the UCITS Directive, which covers mainstream, retail-facing funds rather than alternative ones. AIFMD 2 came into force in April 2024, giving countries until 16 April 2026 to write it into their own national law. That deadline has now passed, but not every country got there at the same pace. Germany, Luxembourg and Ireland had their rules ready early, while France, Belgium, Italy and Spain were still finishing theirs. So, if you operate across borders, don't assume the rules look identical everywhere just yet.
The changes are targeted rather than a full rewrite, but they hit some of the most demanding parts of AIFM compliance. Annex IV reporting used to focus only on a fund's "main" markets and exposures. Now it covers everything, so managers need to report a much fuller picture of their holdings. Firms get an extra year to actually submit reports on the new template (until April 2027), but they're expected to have the data ready to capture from April 2026.
Delegation reporting also goes much further. AIFMs now have to disclose how many in-house staff work on portfolio and risk management, name any firms they delegate to (and sub-delegate to), say what proportion of assets is delegated, and show evidence they're properly overseeing those arrangements. They also now have to report every EU country where each fund is marketed.
Funds that lend money directly (loan-originating AIFs) face a new set of rules. There's now a formal definition of what counts as loan origination, caps on how much they can borrow themselves (175% of fund value for open-ended funds, 300% for closed-ended funds), a requirement to keep 5% of every loan on their own books, and a ban on funds that exist purely to originate loans and immediately sell them on.
Finally, open-ended funds (both AIFs and UCITS) must now pick at least two tools for managing investor withdrawals during stressed markets, such as limiting redemptions temporarily, adjusting the fund's price to reflect trading costs, or charging an exit fee, and tell investors which ones they use. UCITS funds also get a new reporting duty of their own, similar to what AIFMs already have to do.
Passing the deadline doesn't mean the picture is settled. The European Commission has pushed back some of the finer technical detail, including the specifics on liquidity tools and loan-originating funds, until after October 2027. Until those details are confirmed, individual regulators have some room to interpret the rules their own way. So it's worth checking how each country you operate in is applying AIFMD 2, rather than assuming every EU market is doing it identically.
No. The UK kept its own version of AIFMD after Brexit, and it isn't adopting AIFMD 2. Instead, the FCA is working on its own overhaul of the UK rules. On 14 July 2026, the FCA published a consultation paper (CP26/28) proposing to sort AIFMs into three size bands (small, medium and large), with rules that scale to match, and to bring everything together into one new rulebook instead of the current patchwork. The consultation runs until 14 October 2026, alongside related work on fund reporting and pay rules. The Treasury is consulting on the legal changes needed at the same time, and the new UK regime isn't expected to take effect until around 2028.
ARKK has supported Annex IV filing for fund managers across Europe for over a decade. Our regulatory reporting portal takes care of AIFMD XML conversions, with built-in validation rules that reflect the latest ESMA requirements, so template and taxonomy changes are handled in the background rather than becoming a last-minute scramble.
This is backed by an on-hand customer success team, ISO 27001 certification in information security, and trust from more than 65% of the FTSE. If you'd like to talk through how AIFMD 2 affects your reporting process, get in touch with our team.