Insight

AIFMD II – what’s changing?

Lillie Canfield
April 14, 2026

The 16 April 2026 transposition deadline is upon us, so what does AIFMD II actually mean in practice, particularly for Annex IV reporting?

In short, reporting is about to become broader, more detailed, and more consistent across regimes.

ESMA’s technical standards are still to come, but the direction is clear. Firms should expect to submit their first reports under the new framework in Q1 2027.

At the same time, UCITS VI will introduce a new supervisory reporting regime for UCITS management companies – expected to closely mirror AIFMD Annex IV and drive greater alignment across both frameworks.

Key dates

15 April 2024
AIFMD II entered into force, starting the 24-month implementation period.
16 April 2026
Deadline for national transposition.
16 April 2027
New reporting obligations apply. ESMA RTS and ITS are expected in H2 2026, leaving a limited implementation window ahead of Q1 2027 reporting.

What’s changing?

1. Broader, more granular data

The shift away from high-level reporting is significant.

“Principal markets” and “main exposures” will give way to reporting across all relevant instruments, exposures, and markets.

In practice, that means more data, more granularity and more complexity.

The framework will also rely more heavily on standard identifiers to link reported data to other supervisory datasets. While this should improve consistency and comparability, it may present challenges — particularly for asset classes where identifiers are less developed.

2. Increased focus on governance and delegation

AIFMD II places much greater emphasis on how firms are structured and how delegation operates in practice.

Reporting will need to capture:

Delegation chains
Clear identification of delegates and sub-delegates, including location and regulatory status
Scope of delegation
Whether portfolio management, risk management, or both — and the extent of activities covered
Substance and resources
Information on personnel and resources involved in both execution and oversight
Oversight and controls
Evidence of ongoing monitoring, including due diligence, identified issues, and remediation timelines

The key message from regulators is clear: firms need to demonstrate that delegation is actively managed, not just documented.

3. Expanded reporting on cross-border distribution

There is also a sharper focus on where funds are marketed.

Managers will be required to report each EU Member State where a fund is distributed, giving regulators greater visibility over cross-border activity.

What about UCITS?

AIFMD II is not just about alternatives.

As part of the wider package, amendments to the UCITS Directive (commonly referred to as UCITS 6) will introduce a formal supervisory reporting obligation for UCITS management companies.

For the first time, firms will need to report to their home regulator on each UCITS they manage.

While final details are still pending, the regime is expected to closely mirror Annex IV, covering:

Trading activity and exposures
Assets and liquidity
Risk profile and stress testing
Delegation arrangements
Marketing and distribution

These requirements are also expected to apply from April 2027, supported by ESMA’s RTS and ITS.

Summary

AIFMD II represents a clear step change in supervisory reporting:

More data
More detail
Greater scrutiny of governance and delegation
Increased alignment between AIFMD and UCITS

Even with technical standards still to come, firms should already be assessing data availability, systems, and internal processes to ensure they are ready for 2027.

ESMA’s regulatory technical standards (RTS) and final guidelines on Liquidity Management Tools (LMTs) as required under AIFMD II. Additional guidelines published in March 2026.